…s Opposition to Defendant’s Motion for Rule 37(b) Sanctions. 2. Attached as Exhibit O (filed under seal) are true and correct copies of medical records bates labeled GIUFFRE 6631-6635, designated as Confidential under the Protective Order. 3…
… 27 (Giuffre “described Maxwell’s role as one of the main women who Epstein used to procure under-aged girls for sexual activities 1 Defendant has labelled her entire deposition transcript as Confidential at this time. 1 Case 1…
… 27 (Giuffre “described Maxwell’s role as one of the main women who Epstein used to procure under-aged girls for sexual activities 1 Defendant has labelled her entire deposition transcript as Confidential at this time. 1 Case 1…
…include. It is Plaintiff’s understanding from the meet and confer process that Defendant Maxwell’s submission may also include labeling certain docket entries as including information that was put forth in Defendant’s view for an “improper purpose.” Defendant…
…to Plaintiff’s Opposition to Defendant’s Motion To Reopen Plaintiff’s Deposition. 2. Attached as Exhibit O (filed under seal) are true and correct copies of select pages of Plaintiff’s medical records bates labeled GIUFFRE 5089, 5316-18…
…01.27 re: legal advice 21. 2015.04.22 E-mail 7 pages Jeffrey Epstein Ghislaine Maxwell Common Interest Forwarding Common Interest Privilege …
… 27 (Giuffre “described Maxwell’s role as one of the main women who Epstein used to procure under-aged girls for sexual activities 1 Defendant has labelled her entire deposition transcript as Confidential at this time. 1 and a primary…
…WITNESS: I did. 18 MS. SCHULTZ: If you're talking about the 19 document that he brought with him, I had it 20 Bates labeled. 21 MR. PAGLIUCA: We can show him that. I 22 think I have the same…
… 27 (Giuffre “described Maxwell’s role as one of the main women who Epstein used to procure under-aged girls for sexual activities 1 Defendant has labelled her entire deposition transcript as Confidential at this time. 1 and a primary…
…01.27 re: legal advice 21. 2015.04.22 E-mail 7 pages Jeffrey Epstein Ghislaine Maxwell Common Interest Forwarding Common Interest Privilege …
…WITNESS: I did. 18 MS. SCHULTZ: If you're talking about the 19 document that he brought with him, I had it 20 Bates labeled. 21 MR. PAGLIUCA: We can show him that. I 22 think I have the same…
… 27 (Giuffre “described Maxwell’s role as one of the main women who Epstein used to procure under-aged girls for sexual activities 1 Defendant has labelled her entire deposition transcript as Confidential at this time. 1 Case 1…
…untrue." Complaint, DE I, at ,i 31. 1 Defendant has labelled her entire deposition transcript as Confidential at this time. Counsel for the parties conferred at the deposition regarding answering questions. Yet during her deposition, Defendant refused to answer…
…01.27 re: legal advice 21. 2015.04.22 E-mail 7 pages Jeffrey Epstein Ghislaine Maxwell Common Interest Forwarding Common Interest Privilege …
…at ¶ 31. 1 Defendant has labelled her entire deposition transcript as Confidential at this time. Counsel for the parties conferred at the deposition regarding answering questions. 1 Case 1:15-cv-07433-LAP Document 143 Filed 05/05/16…
… 27 (Giuffre “described Maxwell’s role as one of the main women who Epstein used to procure under-aged girls for sexual activities 1 Defendant has labelled her entire deposition transcript as Confidential at this time. 1 Case 1…
…of New York v. Meridien Biao Bank Tanzania, Ltd., 171 F.R.D. 135 (S.D.N.Y. 1997).................................................................................................6 Barrett v. Forest Labs., Inc., No. 12-CV-5224 (RA), 2015 WL 4111827 (S.D.N.Y. July 8, 2015) …
…Since the term ‘public interest’ is flexible, a judicial determination must be made on the specific facts of each case to determine if sufficient potential harm to the public interest exists to render the privilege operable.” Labarbera v. Ulster Cty…
…24, 2016, and designated by Plaintiff as Confidential under the Protective Order. 10. Attached as Exhibit I (filed under seal) is a true and correct copy of medical records bates labeled GIUFFRE005498-005569, produced by Plaintiff on June 1, 2016…
…01.27 re: legal advice 21. 2015.04.22 E-mail 7 pages Jeffrey Epstein Ghislaine Maxwell Common Interest Forwarding Common Interest Privilege …
Comments