…The time to negotiate search terms has long passed; this Court should not countenance Defendant profiting from her refusal to comply with her discovery obligations and from her refusal to obey this Court’s Order. Dated: August 1, 2016 Respectfully…
…The time to negotiate search terms has long passed; this Court should not countenance Defendant profiting from her refusal to comply with her discovery obligations and from her refusal to obey this Court’s Order. Dated: August 1, 2016 Respectfully…
…redacted (“Sealed Materials”). Paragraphs 3 and 5 required that any party contending a Sealed Material should remain sealed or redacted submit a letter brief providing the reason each such material should remain sealed or redacted. On November 19 the Court…
…or information which will improperly annoy, embarrass, or oppress any party, witness, or person providing discovery in this case, Purposes And Limitations Formatted: List Paragraph, Indent: First line: …
…discovery and dissemination of confidential information or information which will improperly annoy, embarrass, or oppress any party, witness, or person providing discovery in this case, IT IS ORDERED: 1. This Protective Order shall apply to all documents, materials, and information, …
…both sealed and unsealed) because it references Paragraph 1 of the Order which would mean that the parties would be providing the Court with names that are already in the public domain as they were named in unsealed pacer filings…
…Edwards, AC Privilege and McCawley and legal assistant re seeking Work Product/joint 5/4/2015 information to assist in providing legal advice, with defense…
…which provided “or information which will improperly annoy, embarrass or oppress any party, witness or person providing discovery in the case.” There are a number of problems with Defendant’s proposed language, for example, evidence that demonstrates that Maxwell engaged…
…the police reports demonstrate Plaintiff’s tumultuous home life, bearing no relationship to any press statements or alleged defamation and providing alternative causation to any of Plaintiff’s now-claimed emotional distress. It makes perfect sense that Plaintiff would want…
…however, they never provided a copy of their redactions and therefore we were required to proceed without them. We began providing Ms. Maxwell’s counsel with our proposed redactions on Saturday, July 25, 2020 but still have not received a…
…Persons, any such Designated Person shall agree to be subject to the terms of this Order by signing a copy hereof and stating that they “Agree to be bound by the terms herein,” and providing such copy to Defense Counsel…
…problems with Plaintiff’s position. First, many of the Non-Parties never received the Notice at all. Defense counsel was charged with providing notice to 91 Non-Parties. Of those: 12 had no known addresses, 18 had Notices that were…
…essential facts leading to Ms. Maxwell’s July 2016 deposition: • Plaintiff moved to compel the deposition, promising that “any answers will be maintained as confidential under the Protective Order in this case” (Brief at 2); • Ms. Maxwell objected to the…
…2023, submit to the Court for in camera review an affidavit supporting her assertion that she faces a risk of physical harm in her country of residence and providing detail concerning the hate mail she received. Doe 107's counsel…
…orders, seeks to “protect the discovery and dissemination of confidential information or information that will improperly annoy, embarrass, or oppress any party, witness, or person providing discovery in [Giuffre v. Maxwell].” (See Memorandum & Order, dated July 1, 2020 [dkt. no…
…Ms. Maxwell has filed well-founded motions in limine to exclude the testimony of both Dr. Kliman and Professor Coonan prohibiting from providing their credibility and vouching opinions. This is the subject matter of Dr. Esplin’s rebuttal report which…
…recall. 18 Q. And when you went into his bedroom, were 19 you under the belief that it was going to be you 20 providing some sort of a massage? 21 A. It certainly didn't involve any sexual 22…
…joint [email protected] defense/common 4/10/2015 m,brad@pat interest/work 56 14:59 Sigrid McCawley robi…
…at 9.) Third, the Court found that parties providing documents and testimony in Maxwell reasonably relied on the Maxwell protective order, whose promises of confidentiality “functioned as a powerful mechanism for inducing parties to provide …
…identifying the information that should remain sealed and the reasons for continued sealing exclusively with the Defendant. We request clarification of the Order. Providing the “reason” a particular document should remain sealed can be accomplished in summary fashion, e.g.…
Comments