…judicial machinery as an expansive civil grand jury to extract and coerce witnesses to reveal private, sensitive and confidential information. Having acquired the information and having gratuitously submitted much of the information in sealed court submissions, Ms. Giuffre changed course…
…Ms. Giuffre’s confidentiality designation. See McCawley Decl. at Exhibit 1, 1 Notably, it appears that Defendant acquired these materials in April, but held onto them without producing them to Ms. Giuffre until after her Ms. Giuffre’s May 3…
…However, logic would dictate that if the police reports are “relevant,” so, too, is the information contained therein and how it was acquired. For that reason, this Court should grant Ms. Giuffre’s requests Nos .1-3. Defendant states that…
…However, logic would dictate that if the police reports are “relevant,” so, too, is the information contained therein and how it was acquired. For that reason, this Court should grant Ms. Giuffre’s requests Nos .1-3. Defendant states that…
…a Receiving Party (a) that is or has become publicly known through no fault of the Receiving Party; (b) that is lawfully acquired by or known to the Receiving Party independent of the Producing Party; (c) that was previously produced…
…of this information, Barden specifically added that the source was “entirely” his client – the Defendant: “The content of the statement was entirely based on information I acquired in connection with my role as counsel for Ms. Maxwell.” Id. at 7…
…Dean of Students, Mr . , We requested to speak with ••■■M••• C was re interviewed, as she still was in possession of the rental car that Epstein had acquired for her. ■ stated that Sarah, Epstein's assistant, had called her…
…Font: 12 pt (a) that is or has become publicly known through no fault of the Receiving Party; (b) that is lawfully acquired by or known to the Receiving Party independent of the Producing Party; (c) that was previously produced…
…Dean of Students, Mr . , We requested to speak with ••■■M••• C was re interviewed, as she still was in possession of the rental car that Epstein had acquired for her. ■ stated that Sarah, Epstein's assistant, had called her…
…The pro-Israel billionaire that made Jeffrey Epstein Although it remains a mystery (http://www.thedailybeast.com/articles/2015/01/06/i-tried-to-warn-you-about-sleazy- billionaire-jeffrey-epstein-in-2002.html) just how Epstein acquired his wealth…
…Font: 12 pt (a) that is or has become publicly known through no fault of the Receiving Party; (b) that is lawfully acquired by or known to the Receiving Party independent of the Producing Party; (c) that was previously produced…
…Dean of Students, Mr . , We requested to speak with ••■■M••• C was re interviewed, as she still was in possession of the rental car that Epstein had acquired for her. ■ stated that Sarah, Epstein's assistant, had called her…
…Defendant should produce the requested documents. If such documents were obtained in contravention of Florida Statutes, it cannot be hidden behind a production of later-acquired police reports. Accordingly, the Court should compel production of these documents. 5 ii…
…by [the party] for the purpose of communicating with their lawyers in confidence, their contents have acquired no special protection from the simple fact of being turned over to an attorney.”); Astra Aktiebolag v. 4 Plaintiff concedes that the items…
…Order, DE 1097 (as amended by DE 1104), we write regarding the proposed disclosure of confidential Maxwell materials requested by Alan Dershowitz – his fourth attempt to acquire Maxwell materials subject to the Protective Order, DE 62 (the “Protective Order”). Second…
…65 L. Ed. 2d 973 (1980)(“Instead of acquiring information about trials by firsthand observation or by word of mouth from those who attended, people now acquire it chiefly through the print and electronic media . . . validat[ing] the media claim…
…In such cases, but for the protective order, the party seeking that testimony would be unable to acquire it. … Conversely, where the parties have not given up any rights and Case 1:15-cv-07433-LAP Document 1106…
…Sealed Op. 22-23. Although Mr. Dershowitz comes before the Court today with a different purpose—to acquire discovery materials in this case to “defend himself,” now in his own case—the result must be the same. One, he seeks…
…many roles it is impossible to believe that he would be able to, ethically, restrict use of information that he acquires in this litigation should it be helpful to the Plaintiff in another context. Mr. Edwards’s multiple conflicting interests…
…always be compelled to dis close his own knowledge of relevant facts. (2) A corporation generally has to acquire knowledge of relevant facts through the written communi cations of its agents. (3) It would be extraordinary if a corporation could …
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