…the subpoena served on Ms. Ransome seeks documents that are wholly irrelevant to the underlying action including protected financial information and documents or communications between Sarah Ransome and her attorneys, which are protected by the attorney- client privilege and the…
…of the parties to this action by blood 16 or marriage, and that I am in no way interested 17 in the outcome of this matter. 18 IN WITNESS WHEREOF, I have hereunto set 19 my hand this 24th day…
… I don't have the 3 date in front of me. I'm sorry. 4 THE COURT: That solves that problem. I have the 5 joint interest agreement. It's been submitted. It occurs to 6 me that it is…
…6, 7 Lytle v. JPMorgan Chase, 810 F. Supp. 2d 616 (S.D.N.Y. 2011) ................................................................................................ 3, 6 Natixis Financial Products LLC v. Bank of America, N.A., 10 Civ. 3656, 2016 WL 7165981 (S.D.N.Y., Dec. 7…
…2. Ms. Giuffre’s Claims Of Attorney-Client Privilege, Work Product Privilege, and Common Interest Privilege Are Appropriate, And Defendant’s Argument On This Point Is Meritless .........................................11 3. Ms. Giuffre Is Not Withholding Information …
…weight of presumption of public access that should be afforded to an item, (b) the identification and weight of any countervailing interests supporting continued sealing/redaction of the item, and (c) whether the countervailing interests rebut the presumption of public…
…the subpoena served on Ms. Ransome seeks documents that are wholly irrelevant to the underlying action including protected financial information and documents or communications between Sarah Ransome and her attorneys, which are protected by the attorney- client privilege and the…
…all Financial Statements prepared for or submitted to any Lender or Investor for the past three years by You personally or on Your behalf or on behalf of any entity in which You hold or held a controlling interest from…
…all Financial Statements prepared for or submitted to any Lender or Investor for the past three years by You personally or on Your behalf or on behalf of any entity in which You hold or held a controlling interest from…
…Court of the countervailing interests prohibiting unsealing. Nor has anyone been given the opportunity to advocate on behalf of the individuals, who may or may not have actually received their notices, or worse, are not in a financial position to …
…Declaration of Laura Menninger (“Menninger Decl.”) at Ex. A, Plaintiff’s Privilege Log. Documents are also were improperly withheld on the basis of joint defense and/or common interest privileges. Id. The categories of improperly withheld documents include: 1) communications…
…privilege, the attorney work product privilege, joint defense/common interest privilege, the agency privilege, investigative privilege, spousal privilege, accountant client privilege, and any other applicable privilege. Ms. Giuffre objects to this request in that it seeks personal financial information. Ms…
…that Does 73 and 93 were not “involved in any of the conduct underlying this action” or “accused of any wrongdoing” because they worked for Epstein in a “financial capacity” or because Plaintiff could not remember their names at deposition. …
…a presumption of access, and with one limited exception regarding financial documents, no countervailing interest has been identified that would warrant sealing any of these documents. Category 5: Objections to Trial Deposition Designations and Counter-Designations Ms. Maxwell offers no…
…the public in order to advance and carry out his crimes and torts. At all relevant times, Defendant Epstein owned and continues to own, directly or through nominee individuals used to conceal his interests, a fleet of airplanes, motor vehicles…
…15 15. Defendant also demands items like personal financial documents from this non-party including payments she received from convicted sex offender Jeffrey Epstein and the men he “lent” this minor child out to from 1999 – 2002. See Exhibit 6…
…it seeks financial information from her when she was a minor child starting at age 14. Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, the attorney work product privilege, joint defense/common interest privilege…
…have concluded that the privacy interests of individuals were sufficient to overcome the presumption of access involve illness or sensitive personal financial information.” Lytle, 810 F. Supp. 2d at 629. And it is generally the privacy interests of “innocent third…
…these six witnesses. See Rule 26d)(3) (“Unless the parties stipulate or the court orders otherwise for the parties’ and witnesses’ convenience and in the interests of justice: (A) methods of discovery may be used in any sequence, and (B…
…information that is protected by any applicable privilege, including but not limited to, attorney client privilege, work product privilege, joint defense/common interest privilege, public interest privilege, and any other applicable privilege. Ms. Giuffre objects to the requests to the…
Comments