…to intervene for the purpose of moving to unseal and make public a hypothetical set of documents that TGP speculates identify a group of non-parties in this action who allegedly “abused girls trafficked by Jeffrey Epstein and Defendant Maxwell…
…INTRODUCTION ................................................................................................................. 1 FACTUAL BACKGROUND ................................................................................................. 2 I. PLAINTIFF’S FAILURE TO IDENTIFY THE SPECIFIC QUESTIONS CLAIMED UNANSWERE…
…2 I. PLAINTIFF’S PRODUCTION OF KEY DOCUMENTS AFTER HER DEPOSITION NECESSITATES ADDITIONAL EXAMINATION ............................................................. 2 A. Plaintiff failed to identify her health care providers and produce their records prior to her deposition, despite this Court’s order …
…INTRODUCTION ................................................................................................................. 1 FACTUAL BACKGROUND ................................................................................................. 2 I. PLAINTIFF’S FAILURE TO IDENTIFY THE SPECIFIC QUESTIONS CLAIMED UNANSWERE…
…55, 56, 73, 93 and 151’s Objections to Unsealing on the public docket with redactions. The brief contains information that may identify certain non-parties, and, in an abundance of caution, Plaintiff has redacted that information pending disposition of…
…Party Doe 133’s September 29, 2023, Memorandum of Law and Objection on the public docket with redactions. The brief contains information that may identify certain non-parties, and, in an abundance of caution, Plaintiff has redacted that information pending…
…56, 73, 93 and 151’s Objections to Unsealing on the public docket with redactions. The brief contains information that may identify certain non-parties, and, in an abundance of caution, Plaintiff has redacted that information pending disposition of the…
…147, 171, and 183’s Objections to Unsealing on the public docket with redactions. The brief contains information that may identify certain non-parties, and, in an abundance of caution, Plaintiff has redacted that information pending disposition of the non…
…56, 73, 93 and 151’s Objections to Unsealing on the public docket with redactions. The brief contains information that may identify certain non-parties, and, in an abundance of caution, Plaintiff has redacted that information pending disposition of the…
…Order (DE 998). It is the parties’ understanding that the purpose of this exercise is to identify for the Court the names of non-parties that are referenced in the sealed filings for notice purposes. Paragraph 2 of the Court…
…2. If the Court grants Dershowitz’s request for pre-Answer discovery, Giuffre expects that she will also be allowed to identify and publish sealed materials in response to Dershowitz’s forthcoming counterclaims. Sincerely, /s/ Sigrid McCaw…
…who are alleged to have been victimized. 1 Case 1:15-cv-07433-LAP Document 1037-1 Filed 03/26/20 Page 2 of 14 The Non-Parties List will: • Identify each Non-Party by his or her name…
…of “any and all documents” filed in Giuffre v. Maxwell that “identify the men who abused the girls trafficked by Jeffrey Epstein and Defendant Maxwell.” Appellant’s App’x at 260. The District Court denied TGP’s motion to intervene…
…15-cv-07433-LAP Document 1196 Filed 01/27/21 Page 3 of 32 3 1 materials; (2) identify and evaluate the weight of any 2 countervailing interests; and (3) determine whether the 3 countervailing interests rebut the presumption. 4 …
…the Protocol will require the parties to “identify[] the most current address available for [a non-party] in a public records database or other readily available source.” This will ensure that the notice to non- parties is “the best practicable…
…documents. 6 As you know, the Second Circuit released certain documents. We 7 have had a team at our firm trying to go through and identify 8 where, if at all, those show up with within the documents that 9…
…one, evaluate the 22 weight of the presumption of public access to the materials; 23 and two, identify and evaluate the weight of any countervailing 24 interests; and 3, determine whether the countervailing 25 interests rebut the presumption. The presumption…
…1115), we determined that in compiling the declaration, Plaintiff’s counsel used the incorrect Non-Party pseudonyms to identify certain Non-Parties because counsel was relying on a prior, outdated version of the Non- Party list. 5. I therefore submit…
…that the failure to identify the 7 individuals to whom the statement allegedly was made and the 8 content of that statement is fatally defective to an attempt to 9 state a libel or slander cause of action. 10 In…
…your Rule 26 disclosures. However, you never submitted a RFP seeking all - communications between our client and your witnesses. There are some RFPs which identify individual witnesses whose communications with our client you sought (e.g.,…