…APPEAR AND RESPOND . 10 IV. MS. RANSOME MUST BE REQUIRED TO PRODUCE REPONSIVE DOCUMENTS THAT HAVE BEEN WITHELD WITHOUT BASIS, AND IDENTIFY ANY OTHER DOCUMENTS WITHELD ................................................................................................... 12 CONCLUSION .............................................…
…names and 16 substituting initials and things like that. They don't 17 identify the names of victims of sexual assaults. 18 But the law is such that we have to decide what 19 standard applies. But in any event…
…this case, including subparts, in violation of Rule 33. Ms. Giuffre objects to Defendant’s Discovery Requests to the extent they seek information that is protected by any applicable privilege, including but not limited to, attorney client privilege, work product…
…opinion, the Second Circuit suggested in dicta that “[t]he District Court may also order the parties to identify and notify additional parties whose privacy interests would likely be 1 Based on lessons learned from past rounds of unsealing, 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…
…First, the court must take note of the elements a plaintiff must plead to state a claim. Second, the court should identify allegations that, because they are no more than conclusions, are not entitled to the assumption of truth. Finally…
…Court or any Orders of the Court. 3. Ms. Maxwell objects to the Requests to the extent they seek documents or information protected by the attorney/client privilege, the work-product doctrine, Rule 408 of the Federal Rules of Evidence…
…it seeks information protected by the attorney-client 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. 13. Identify any Health Care Provider…
…presumption of access to these documents, the Court should also find that Ms. Maxwell and J. Doe have failed to identify any non-generalized, non-speculative interest that would outweigh these First Amendment and common law rights of access. Therefore…
…10 IV. MS. RANSOME MUST BE REQUIRED TO PRODUCE REPONSIVE DOCUMENTS THAT HAVE BEEN WITHELD WITHOUT BASIS, AND IDENTIFY ANY OTHER DOCUMENTS WITHELD ................................................................................................... 12 CONCLUSION ..................................................................…
…irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Maxwell further objects to this Request to the extent it seeks documents or information protected by the attorney/client privilege, the work-product doctrine…
…one of the largest and 17 most significant pieces to us are the assertions by plaintiff 18 that her own communications with law enforcement are somehow 19 protected by -- 20 THE COURT: I'm prepared to deal with that. 21 …
…under Brown’s footnote 5. Throughout its brief the Miami Herald argues we failed to identify a compelling or other countervailing interest that would outweigh a presumption of access or we failed to carry our burden of establishing such an…
…conclusory remark does not negate the strong public interest in this action, and it is not Plaintiff’s burden to identify why disclosure would serve the public interest—it is presumed under the presumption of public access. See July 23…
…1:15-cv-07433-LAP Document 66 Filed 03/23/16 Page 13 of 35 13 G3hdgium 1 THE COURT: You get it. 2 MS. MENNINGER: It is copyright and proprietary 3 protected. We're not going to produce it…
…and Work Product Privileges by Putting Plaintiff’s Representation At Issue in the Dershowitz Case “The [attorney-client] privilege may implicitly be waived when [a party] asserts a claim that in fairness requires examination of protected communications.” United States v…
…information itself (ii) These acts may be reqtJired only as directed in the order, and the privileged or protected, will enable the parties to asses.~ the claim. order must protect a person who is neither a party nor a…
…Maxwell still cannot, however, identify any countervailing interests that would overcome the presumption of public access to these judicial documents. The publication of Maxwell’s deposition testimony is in the public interest. Maxwell’s brief concedes (as it must) that…
…of a protective order, regardless of whether a party later seeks – or acquiesces to – the release of that information. Those non-parties “have a right to be protected against becoming victims of litigation cross-fire.” Minpeco, S.A. v. Conticommodity…
…and Work Product Privileges by Putting Plaintiff’s Representation At Issue in the Dershowitz Case “The [attorney-client] privilege may implicitly be waived when [a party] asserts a claim that in fairness requires examination of protected communications.” United States v…