…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…
…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…
…Florida’s open-records laws. Subsection (2)(h)1.b. provides that “the identity of a person who is a victim of any sexual offense” (emphasis supplied) is exempt from the open-records laws. Here, the defense obtained identity-redacted…
…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…
…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…
…protected from public dissemination by Florida law. Specifically, Florida statutes protect “[a]ny information in a videotaped statement of a minor who is alleged to be or who is a victim of sexual battery . . . which reveals that minor’s identity…
…the motion briefly proffered the circumstances that would qualify the two women as “victims” eligible to assert rights under the CVRA. See 18 U.S.C. 3771(e) (defining “crime victim” protected under the Act). With regard to Ms. Giuffre…
…the motion briefly proffered the circumstances that would qualify the two women as “victims” eligible to assert rights under the CVRA. See 18 U.S.C. 3771(e) (defining “crime victim” protected under the Act). With regard to Ms. Giuffre…
…Statutes Plaintiff also cites Colorado statutes which, she claims, support the proposition that her identity as the victim of domestic violence is protected by Colorado law. It is not. Section 13- 90-107(k),3 is a testimonial privilege statute…
…limit. Plaintiff’s invocation exceeded what is protected under well-settled law. 11 Case 1:15-cv-07433-LAP Document 75 Filed 03/31/16 Page 17 of 31 Plaintiff refused to identify all attorneys who represent her, the…
…354 Filed 08/10/16 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…
…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…
…which Ms. Maxwell is a target. First, Plaintiff claimed that the documents were protected by a non-existent “investigative privilege.” When Ms. Maxwell demonstrated that the “investigative privilege” does not exist, Plaintiff threw up the inapplicable “public interest” privilege, the…
…which is Giuffre v. Maxwell redux. It is plaintiff’s familiar litigation template: Identify a prominent person with any ties to Jeffrey Epstein, go to the media, make false allegations that that person participated in Mr. Epstein’s “sex trafficking…
…1 B. Ms. Maxwell’s Statement In Context Is Not Defamatory ................................... 3 II. MS. MAXWELL’S STATEMENTS ARE PROTECTED BY PRIVILEGE .......... 6 A. Qualified Privilege May Form the Basis for a Rule 12(b)(6) Dismissal ............. 6 B. Ms. Maxwell…
…every rule applicable to motions to compel: her counsel did not confer; the motion fails to identify any discovery request it is seeking to “compel” a response to; and it failed to list verbatim any such allegedly unanswered discovery request…
… Good afternoon. 23 MR. KRIEGER: Good afternoon, Judge. 24 THE COURT: Is there any party or non-party who I have 25 missed who wishes to identify himself or herself? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 Case…
…communication. 13. Identify the basis, including all underlying facts, for your contention that Plaintiff’s claims are barred because the statements made by Ms. Maxwell or her agent were protected by the self-defense privilege. ANSWER: Ms. Maxwell objects to…
…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…
…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…