…Maxwell defendants, take no 14 position on our application. Judge Koeltl has expressed a 15 willingness to consider the information that we are seeking by 16 way of this modification. 17 THE COURT: Incidentally, as I understand it, what we…
…delay, Ms. Giuffre stated that she would be willing to “agree to a reasonable Protective Order being in place in this case” and attached a redlined version of Defendant’s proposed Protective Order. 1 See McCawley Decl. at Exhibit 4…
…protective order the parties supposedly “relied on” in making the productions. Yet, the Second Circuit ordered these materials released to the public (not just to another party willing to follow the protective order, as Dershowitz proposes here). In doing so…
…I certainly do feel that down the long, winding road, your case has merit! God willing that it puts that piece of human scurr back behind bars! Should you win the day, yes, T do believe that you can create…
…has already asserted objections on her own behalf to many of the documents that will be at issue. In any event, Plaintiff is willing to confer with Maxwell in good faith to address ways to alleviate her burden. For example…
…4, 2016, Plaintiff represented in Response that she “is willing to produce the Settlement Agreement and all documents concerning the Settlement Agreement if Defendant gets a waiver of liability from Jeffrey Epstein for its disclosure.” Doc. #78 at 15. Indeed…
…is whether the plaintiff would be willing to accept a form of sworn statement in response to questions whereby Epstein invokes his Fifth Amendment privilege in lieu of Epstein having to sit for a formal in-person deposition. 3 Case…
…July 13, 2016 8:22 PM To: Jeff Pagliuca Subject: Fwd: Your motions Jeff, Look I'm not going to be dragged into these nonsense emails. I'm willing to help clear up miscommunication if that indeed occurred. However, I…
…McCawley indicated on the record that she did not oppose an adjournment. In Plaintiff’s Reply, she indicated that she would be willing to make an additional attempt to confer before rescheduling the hearing on the Motion. Reply at 3…
…s decision to request a stay based solely on vague allusions to “critical new information” illustrates her disregard for the Court’s time, as well as her willingness to engage in dilatory conduct to thwart the unsealing process. See Dkt…
…any individual to whom CONFIDENTIAL information was shared pursuant to Paragraph 6 (and from whom there must be a written acknowledgment of their willingness to abide by the Protective Order): o The attorney who shared the CONFIDENTIAL information will obtain …
…of public record. We respectfully submit that plaintiff Ms. Giuffre and her counsel should not be permitted to abuse the Court’s willingness to accommodate the parties’ need to protect truly confidential materials in this way. Moreover, these improper redactions…
…the FBI has indicated a willingness to produce and deliver the original photographs to this Honorable Court upon receipt of a Court Order directing the FBI Miami Field Office to deliver the photographs to the Court including instruction from the…
…Ms. Giuffre has been asking for April dates for this deposition since March. After repeated requests, counsel for Defendant was only willing to make Defendant available for deposition the first week of May, on the eve of trial. This motion…
…Civ. P. 1). “If protective orders were easily modified . . . parties would be less forthcoming in giving testimony and less willing to settle their disputes.” S.E.C. v. TheStreet.Com, 273 F.3d 222, 230 (2d Cir. 2001). In particular…
…'” Case 1:15-cv-07433-LAP Dershowitz responded Document by saying that if Boies 363-11 is willing to haveFiled Freeh08/11/16 Page …
…when it gets produced in this case. I 22 am not willing to accept plaintiff's representations on this as 23 to what it is or isn't. I've never had the opportunity to 24 question or cross-examine…
…dkt. no. 1044 in 15 Civ. 7433].) Critically, the agreed-upon unsealing procedure can only work as intended if non-parties are willing to participate. Handing over to Mr. Dershowitz all of the materials from Maxwell, which would necessarily include…
…CONTACT WITH JOSHUA BUNNER AND THIS TIME I WAS SUCCESSFUL. I ASKED JOSH IF HE "WO)JLD BE WILLING TO SPEAK WITH ME IN REGARDS TO AN ONGOING SHERIFF'S OFFft:~~f?J:NVESTIGATION AND HE AGREED TO DO THIS…
…no purchase price for the ticket, because the people who want the testimony are willing to front the cost of the litigation either on a contingency or pro-bono basis.” Defendant’s Combined Motion at 7. Any suggestion of “fabrication…
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