Found 49 results for “harassment” in 333ms

gov.uscourts.nysd.447706.1296.13.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1296.13 15 pg

…asserts, without factual or legal support, that her financial information is being sought “for the purpose of harassment and intimidation.” Because Ms. Ransome failed to address the relevance argument asserted by the Motion, this issue should be deemed admitted. Compare…

gov.uscourts.nysd.447706.1332.12.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1332.12 7 pg

…arbiter in the room. Thus, for efficiency purposes and to protect Ms. Maxwell from harassment and oppression, we request that the Court appoint a Special Master to preside over Ms. Maxwell’s third deposition and be given the following powers: …

gov.uscourts.nysd.447706.1332.7.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1332.7 29 pg

…protecting deponent from annoyance, embarrassment and harassment by denying party’s attempt to obtain personnel records relating to non-party). Courts are more vigilant with these protections when the discovery is being sought from a non-party. “[T]he fact…

gov.uscourts.nysd.447706.503.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.503.0 21 pg

…The Privilege therefore protects "the independence of the press and the need to allow the press to publish freely on topics of public interest without harassment 9 Case 1:15-cv-07433-RWS Document 503 Filed 11/21/16…

gov.uscourts.nysd.447706.1332.8.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1332.8 27 pg

…of privacy. A non-party should not be subjected to undue harassment serving no admissible purpose. 9 Case 1:15-cv-07433-LAP Document 1332-8 Filed 01/08/24 Page 11 of 27 Without waiving such objections, a…

gov.uscourts.nysd.447706.1150.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1150.0 56 pg

…These arguments were made, and documents filed, for purposes of distraction and harassment, and have nothing to do with the issues presented by the motion. This is classic abuse of the courts records and files. The Response and Exhibits were…

gov.uscourts.nysd.447706.1332.9.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1332.9 15 pg

…asserts, without factual or legal support, that her financial information is being sought “for the purpose of harassment and intimidation.” Because Ms. Ransome failed to address the relevance argument asserted by the Motion, this issue should be deemed admitted. Compare…

gov.uscourts.nysd.447706.831.0_2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.831.0_2 59 pg

…own, your Honor, doesn't seem to require a 3 nonparty witness to go through those burdensome and harassment 4 lengths. 5 THE COURT: But those statements have nothing to do 6 with this case. 7 MR. POTTINGER: Well, not…

gov.uscourts.nysd.447706.955.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.955.0 43 pg

…380 F.3d 110 (2d Cir. 2004) (per curiam) (witnesses and third parties "possess strong privacy interests, because being identified as part of a law enforcement investigation could subject them to 'embarrassme nts and harassment'" ), "with the deviant and the…

gov.uscourts.nysd.447706.1219.22.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1219.22 22 pg

…R.D. 391 (E.D.Cal.2009) (evidence of employer's current financial worth was relevant to issue of punitive damages, and thus was discoverable in Title VII action alleging sexual harassment and retaliation, where complaint sought punitive damages, deposition…

gov.uscourts.nysd.447706.1198.29_1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1198.29_1 16 pg

…Giuffre and her attorneys, not to mention the purposes of harassment. Pursuant to the Rules, if requested documents are not yielded in a “reasonable inquiry,” Ms. Giuffre is not obligated to expend all of her time and resources on a…

gov.uscourts.nysd.447706.1328.23.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1328.23 22 pg

…R.D. 391 (E.D.Cal.2009) (evidence of employer's current financial worth was relevant to issue of punitive damages, and thus was discoverable in Title VII action alleging sexual harassment and retaliation, where complaint sought punitive damages, deposition…

gov.uscourts.nysd.447706.1328.4.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1328.4 40 pg

…such an interrogatory is merely for the purpose of imposing a burden on Ms. Giuffre and her attorneys, not to mention the purposes of harassment. Pursuant to the Rules, if requested documents are not yielded in a “reasonable inquiry,” Ms…

gov.uscourts.nysd.447706.1295.17.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1295.17 27 pg

…Request in that it represents a complete invasion of privacy. A non-party should not be subjected to undue harassment serving no admissible purpose. 9 Without waiving such objections, a copy of non-party Sarah Ransome’s current passport…

gov.uscourts.nysd.447706.1334.1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1334.1 29 pg

…protecting deponent from annoyance, embarrassment and harassment by denying party’s attempt to obtain personnel records relating to non-party). Courts are more vigilant with these protections when the discovery is being sought from a non-party. “[T]he fact…

gov.uscourts.nysd.447706.23.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.23.0 32 pg

…knew the statements were false because Defendant engaged in and facilitated the sexual abuse of this minor child, therefore, they were made for the inappropriate purpose of “bullying,” “harassment,” and “intimidation.” See Front v. Khalil, 24 N.Y.3d 713…

gov.uscourts.nysd.447706.1167.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1167.0 31 pg

…These arguments were made, and documents filed, for purposes of distraction and harassment, and have nothing to do with the issues presented by the motion. This is classic abuse of the courts records and files. The Response and Exhibits were…

1320-28.pdf PDF

giuffre-maxwell 1320-28 32 pg

…prostitute I have been the target of outright lies, innuendo, slander, defamation and salacious gossip and harassment; headlines made up of quotes I have never given, statements I have never made, trips with people to places I have never been…

gov.uscourts.nysd.447706.773.4.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.773.4 5 pg

…now in prison, enticed investors by falsely claiming that they could buy into lucrative pending settlements in whistleblower, sexual harassment and other cases. Edwards’ court papers say he knew nothing of Rothstein’s schemes, and federal authorities later determined Edwards…

gov.uscourts.nysd.447706.1137.8_3.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1137.8_3 9 pg

…a plaintiff’s sexual history. The court took guidance from F.R.E. 412, and held that in an alleged sexual harassment case questions about a plaintiff’s prior sexual history would not be allowed. See also, A.W. v…

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