…2007) (agency exception to the attorney-client privilege is inapplicable under New York law to communications with a public relations firm “providing ordinary public relations advice and assist[ing] counsel in assessing the probable public reaction to various strategic alternatives…
…38:A lld ocu ments reflectingcontactwithyou by any law enforcement orpolice agency,inclu d ingany contactby the FB I,P alm B eachP olice D epartment,orW est P alm B eachP olice D epartment. RESPONSE: M s.M ax…
…is the applicable standard; Martindell requires a compelling need or exceptional circumstances to justify government intervention The moving party, a federal agency of the United States, purports to seek both intervention as a matter of right and permissive intervention. (Doc…
…him. Beyond that, the report may be properly admissible under exceptions to the hearsay rule. For example, it seems likely to qualify for admission under Rule 804(8) as a public record for an investigating government agency. Or, if for…
…requests and thus far has produced 4,134 pages of documents. Defendant’s Position: Defendant says Plaintiff should not have listed certain objections like “agency” or “investigative privilege.” Reality: Plaintiff agreed during the meet and confer to revise…
…the subject of “strong current media interest.” Nor does the fact that Professor Dershowitz is not himself a news agency negate his access rights: “The First Amendment generally grants the press no right to information about a trial superior to…
…in this case. Ms. Giuffre objects in that 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…
…Proceedings” (DE 101), seeks to compel Ms. Giuffre to disclose the name of law enforcement agency with which she is cooperating in an investigation into Jeffrey Epstein’s sex trafficking. Defendant has not conferred with Ms. Giuffre on her request…
…Ederi. 3. All Documents containing communications with Jason Richards. 4. All Documents containing communications with law enforcement agency concerning Virginia Roberts. 5. All Documents reflecting any payment of any money to Virginia Roberts. 6…
…this private civil litigant. The public interest privilege holds that “[a]s part of the common law of evidence, ‘official information’ in the hands of governmental agencies has been deemed in certain contexts, privileged.” Cirale v. 80 Pine Street Corp…
…of the obligation to provide a responsive answer. This is a frivolous argument. The Florida laws prohibit Florida agencies from disclosing certain information about sexual assault victims. Plaintiff is not a state agency. None of the laws is relevant to…
… motivation to fabricate) 25. Any Documents containing any Communications You have had with any law enforcement agency. 9 Case 1:15-cv-07433-LAP Document 1331-30 Filed 01/05/24 Page 12 of 19 26. Any Documents that…
…4 of 21 Second, in certain instances, Churcher was also acting as a source for information to Plaintiff’s counsel and law enforcement agencies, specifically stating that she was not acting in her capacity as a journalist. In these instances…
…the State Attorney•• Office; IT APPEARING. aftor an investigation of the oft'emes and Epstein's background by both State and Federal law enforcement agencies, and after due comultation with the State Attorney's Office; that the interests of the…
…agent, attorney, consultant, or representative of Jeffrey Epstein. 9. “Person(s)” includes natural persons, proprietorships, governmental agencies, corporations, partnerships, trusts, joint ventures, groups, associations, organizations or any other legal or business entity. …
…interest in monitoring the courts, but it also has an interest in reviewing the actions of the public agencies who utterly failed to protect and bring justice to Jeffrey Epstein and Ghislaine Maxwell’s victims. See United States v. Massino…
…public’s interest in this litigation, which involved voluminous documents and testimony about Jeffrey Epstein’s transcontinental sex-trafficking operation and documents concerning various public agencies’ utter failure to protect and bring justice to his victims. See United States v…
…435 U.S. 589, 597 (1978) (noting that “the citizen’s desire to keep a watchful eye on the workings of public agencies” is a sufficient basis to compel access). Even if a more concrete stake were needed, Professor Dershowitz…
…and let me know Thanks ever so much Sarah P.S Could you also tel him know that I am going to three different modelling agencies on Monday in search of a PA T…
…Case 1:15-cv-07433-LAP Document 1320-31 Filed 01/03/24 Page 9 of 24 TO: ,JEAN LUC BRL'NEL EXHIBIT A 9. ·'Person(s)'' indudes natural persons, prop1ietorc;hips, governmental agencies, corporations, partnerships, trusts, joint ventures. groups…