…serving party tangible things in a manner that, without revealing information itself may move the court for the district where compliance is required for an privileged or protected, will enable the parties to assess the claim. order compelling production or…
…due to holding both French and British passports, she has the ability to 'live beyond the reach of extradition indefinitely'. Prosecutor Moe argued: 'She is good at living under an assumed identity. There really can be no question that she…
…affirmed by the Second Circuit, found that Ms. Maxwell failed to identify deposition testimony that “constitute[] personal information which might lead to annoyance or embarrassment if unsealed” because, inter alia, she “refused to testify as to any consensual adult activity…
…4 So we are awaiting a ruling. We believe those 5 individuals should be protected under the Court's protective 6 order and those names kept confidential during the course of 7 this, and it is my understanding that defendants…
…that it seeks information protected by the attorney client and work product privileges. Ms. Giuffre objects to this interrogatory in that it is not limited in time or to the subject nature of this litigation. 8. Identify the individuals referenced…
…III. The Applicable Standard Pursuant to Federal Rule of Civil Procedure 4 5 ( c) ( 3) (A), a court "must quash or modify a subpoena that (iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies…
…federal court proceedings. As a result, that filing is indisputably protected by Florida's broad and absolute litigation privilege. Consequently, plaintiffs' motion for summary judgment as it relates to the pending counterclaim against them should also be granted. ARGUMENT II. …
…protected by the attorney-client privilege, the attorney work product privilege, joint defense/common interest privilege, the public interest privilege, and any other applicable privilege. Ms. Giuffre objects in that this request is overly broad and unduly burdensome. 6. Identify…
…at least one press source claimed to “crack” the redactions to identify witnesses and potential testimony by or 3 https://www.npr.org/2020/10/22/926590153/jeffrey-epstein-update-read-the-deposition-that- ghislaine-maxwell-fought-to-hide 4…
…information itself (ii) These acts may be required only as directed in the order, and the privileged or protected, will enable the parties to assess the claim. order must protect a person who is neither a party nor a party…
…These aul, may be reqllired only as directed in the order, und lhe privileged or protected, will enable the parties to assess ille claim. order mllst protect a person who is neither II pHny nor a party'~ "metr tiol!…
…Professional” or “Health Care Institution” in Colorado Revised Statute § 13-64-202(3) and (4). 9. “Identify” means to specify as to a “Person,” the name, address, telephone number and any other identifying information possessed by You or Your Attorneys…
…For other providers, no records were produced. Where no documents were produced, Plaintiff failed to identify the dates and nature of the treatment received, as requested in the Interrogatory. Id. Plaintiff failed therein to identify any treatment providers prior to…
…each category of damages claimed by the disclosing party—who must also make available for inspection and copying as under Rule 34 the documents or other evidentiary material, unless privileged or protected from disclosure, on which each computation is based…
…4 Filed 01/05/24 Page 5 of 40 that Ms. Maxwell has published “numerous” false statements, yet Plaintiff stubbornly refuses to identify each of these allegedly false statements. Interrogatory No. 6 asked simply that for each allegedly false statement…
…DE 144 is a lawyer declaration referencing the exhibits in DE 144-1-7. The declarations accompanying the various Sealed Materials often identify a Non-Party. The Court may wish to simply redact all of the Non-Party names from…
…protected by the attorney-client privilege, the attorney work product privilege, joint defense/common interest privilege, the public interest privilege, and any other applicable privilege. Ms. Giuffre objects in that this request is overly broad and unduly burdensome. 6. Identify…
… "Und er En g.lish Law, commun icati o ns between client and la wyer through an age nt will be protected by l egal advice privilege, but thi s will on ly app ly in sit uations wh ere…
…demonstrates exactly why the Motion was necessary. Not until the Motion was filed did Plaintiff “supplement” her privilege log, specifically identify some of the documents she is withholding, produce relevant documents clearly in her possession, concede to providing information previously…
…that it seeks information protected by the attorney client and work product privileges. Ms. Giuffre objects to this interrogatory in that it is not limited in time or to the subject nature of this litigation. 8. Identify the individuals referenced…
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