…or potential witnesses; and h. any person (1) who authored or received the particular Protected Material; (2) who has or had at any point in time access to the Protected Material outside of the context of this action; or (3…
…15-cv-07433-LAP Document 1218-39 Filed 07/15/21 Page 14 of 36 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…
…or potential witnesses; and h. any person (1) who authored or received the particular Protected Material; (2) who has or had at any point in time access to the Protected Material outside of the context of this action; or (3…
…Such documents do not even require extensive review as they are protected by privilege, and can be categorically logged pursuant to the Local Rules and governing case law.3 Therefore, there is no merit to Defendant’s burden claim. Moreover…
…Plaintiff refused, claiming the laundry-privilege list and stating that the “information is in the possession of Defendant who has failed to comply with her production obligations.” Likewise, Plaintiff refused to identify, in advance of Ms. Maxwell’s deposition or…
…Giuffre’s relationships with her lawyers that Ms. Giuffre’s counsel contends are protected by the attorney-client and work product privileges; Documents relating to prescriptions and medical records that are unrelated to defamation and the sexual abuse she…
…attention from her own conduct. Defendant’s main argument is that discovery should be stayed because Defendant will be successful on her Motion to Dismiss as her defamatory statements are protected by certain qualified privileges. The case law is clear…
…connection with plaintiff’s violation of the Protective Order via her attorneys, the Court should enter orders to determine the nature and extent of the violation of the Order, identify those persons who violated the Order, and impose appropriate sanctions…
…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…
… The Court of Appeals’ Stated Concern For The Publication Of Libelous Statements Protected By The Litigation Privilege Emphasizes This Court’s Responsibility To Protect The Interests Of Non-Parties. While the Court of Appeals ultimately found Judge Sweet erred in…
…2d 260, 263 (S.D.N.Y. 2013) (“the Court notes that Plaintiffs’ letter is a sur-reply filed without permission of the Court and does not identify new controlling law, and therefore will not be considered.”). To the extent…
…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…
…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 …
…of particular CONFIDENTIAL INFORMATION by giving written notice to the party designating the disputed information. The written notice shall identify the information to which the objection is made. If the parties cannot resolve the objection within ten (10) business days …
…production. REPLY ARGUMENT I. Communications between Plaintiffs and Giuffre prior to the formation of the attorney-client relationship in March 2014 are not protected by the attorney- client privilege. As an initial matter, any communications between …
…Ill. May 14, 2008) (“the court finds that the request to identify ‘all documents that refer or relate to each such person's contribution’ to be overbroad and unduly burdensome, and sustains the objection to that part of the interrogatory”)…
…them in plaintiff's account held non-actionable where plaintiff had in fact endorsed checks made payable to the defendant). There are cases where "o ne struggles to identify any area of ambiguity as to truth." Jewell, 23 F. Supp…
…290 F.R.D. 421, 434 (S.D.N.Y. 2013) (“communications are protected where there is a disclosure by A to the attorney representing B and vice-versa”). Therefore, Maxwell’s 4 communications with other parties, outside the presence…
…rendition of legal services by Edwards and Cassell. As long as the Jane Doe #3 has a reasonable expectation of privacy in the communication, under§ 90.507, the privilege is protected. Mcwatters v. Stale, 36 So.3d 613, 636 (Fla…
…manner that, without revealing information itself privileged or protected, will enable other parties to assess the claim.” (emphasis supplied). The Local Rules are even more specific, and require a party withholding a document to identify “(i) the type of document…