…ESI procedures that Ms. Giuffre employed - a procedure endorsed by the case law, by the Southern District of New York,4 the Sedona Conference,5 by e-discovery treatises,6 and by common practice. See Stinson v. City of New…
…Giuffre’s attorneys under the practice of this District. Ms. Giuffre’s attorneys argue it is “common practice” in this District for protective orders to require return of materials “after the completion of all appeals in the case.” Doc.961…
…that the relevant party “may retain all documents subject to the accompanying protective order until its current, and any other, appeals in this case have concluded”). Indeed, “[t]he common practice . . . appears to be for protective orders to require the …
…to have been, disclosed. As to (i) it is common H practice within the industry for oil companies to prepare such reports/analyses following major health and safety incidents which occur during the course of their …
…associate with the law firm of Boies, Schiller & Flexner LLP and duly licensed to practice in Florida and before this Court pursuant to this Court’s Order granting my Application to Appear Pro Hac Vice. 2. I respectfully submit this…
…2 of 4 § 42:178.Public-interest privilege, 7 Carmody-Wait 2d § 42:178 7 Carmody-Wait 2d § 42:178 Carmody-Wait 2d New York Practice with Forms March 2016 Update …
…I am a partner with the law firm of Boies, Schiller & Flexner LLP and duly licensed to practice in Florida and before this Court pursuant to this Court’s September 29, 2015 Order granting my Application to Appear Pro Hac…
…P. 37(a)(3), files this Renewed Motion to Compel Settlement Agreement regarding the confidential settlement agreement between Plaintiff and Jeffery Epstein, and states as follows: INTRODUCTION As part of her scorched earth litigation practice, Plaintiff, without any legal basis…
…the presumption of open access to judicial proceedings and documents under the First Amendment and common law. With trial set to commence in less than two weeks, the practice of filing nearly all substantive submissions under seal has not abated…
…10 Comment: This “public interest” privilege for official government information has been described in the Practice Commentaries as “… a nebulous category presumably subsumed at least in some measure by the Freedom of Information Law and its qualifications and exceptions…
…As it is, I would expect these discrete surnames to yield a reasonable number of “hits,” as most are not common words (more on that below). Per our conversation, there are a number of individuals who we have reason to…
…in part . 8 . Pl aintiff has moved for leave to fi l e an opposit i on brief in excess of the 25 pages permitted under this Court ' s Individual Ru l es of Practice . This motion is granted . I…
…information protected by the attorney/client privilege, the work-product doctrine, Rule 408 of the Federal Rules of Evidence, any common interest privilege, joint defense agreement or any other applicable privilege. 4. Ms. Maxwell objects to the Requests to the…
…Liability Page 3 of20 support. And the statements that he made attack the chosen profession of Edwards and Cassell — the practice of law — and therefore carry with them a presumption of damages suffered. Accordingly, the court should grant plaintiffs' motion…
…without sealing and with the understanding that such 20 documents are publicly accessible. And while the relatively recent history of modern civil discovery practice means there is no ancient common-law analogue to the contemporary discovery motion, “[t]his absence…
…10 G. Legal Advice to a Corporation and Its Officers is Privileged ........................................... 14 H. Attorney-Client Privilege is Clearly Established for all Common Interest and Joint Defense Documents Withheld ...................................................................................…
…motion is granted in part and denied in part. 8 . Plaintiff has ~oved for leave to file an opposition brief in excess of the 25 pages permitted under this Court's Individual Rules of Practice. This motion is granted. r…
…and between (c) defense counsel with joint defense or common interest privileges concerning obtaining or receiving 'local police[] findings or opinions’ and ‘statements 1 Case 1:15-cv-07433-LAP Document 1328-31 Filed 01/05/24 Page 3…
…2. Ms. Giuffre’s Claims Of Attorney-Client Privilege, Work Product Privilege, and Common Interest Privilege Are Appropriate, And Defendant’s Argument On This Point Is Meritless .........................................11 3. Ms. Giuffre Is Not Withholding Information …
…information protected by the attorney/client privilege, the work-product doctrine, Rule 408 of the Federal Rules of Evidence, any common interest privilege, joint defense agreement or any other applicable privilege. 4. Ms. Maxwell objects to the Requests to the…
Comments