…Defendant is in possession of Ms. Giuffre’s signature. C. Ms. Giuffre Has Disclosed Her Address Defendant asserts yet another meritless argument by claiming that Ms. Giuffre has not disclosed her address. First, it is noteworthy that while Defendant complains…
…much less discuss, Florida law, she has not carried that burden.) Defendant asserts that she can force disclosure of the privileged communications between Ms. Giuffre and her counsel under the “at issue” doctrine. To establish this alleged waiver, Defendant’s…
…§ 985.054 make juvenile law enforcement records confidential from members of the public, and states that information obtained by a law enforcement agent participating in the assessment of a juvenile is confidential. Finally, certain of the police reports implicate Ms…
…her Response contains additional impropriety. Plaintiff repeatedly asserts that she has produced and disclosed documents but her chart and her arguments neglect to mention that those documents were only sought and produced after the deposition, indeed up to and including…
…the court as part of the decree-approval process, they were “‘relevant and material” to the process, and the district court “relied upon the documents in assessing the reasonableness of the order, i.e., in determining the litigants’ substantive rights…
…be rcquin:d to produce Jocuments or, at the very least, a privikgc log so that the Court (and opposing counsel) can assess the validity of his claims. Second, Epstl.'!in was asked approximatc'.ly 500 hundred substantive questions at…
…Earlier today, the DOJ released an additional three million pages of Epstein-related records. 4 Maxwell’s counsel asserts that many John Does “relied” on the Protective Order (Dkt. 62) in this case and therefore require an opportunity to object…
…on absolute privileges, whose application required no factual determinations, but could be determined on the face of the pleadings, in contrast to the qualified privileges Defendant asserts here, which require a determination of malice and improper purpose. 883 F. Supp…
…conclusory allegation that she “has a significant interest in knowing about the investigation so that she can appropriately respond and assess any claim of privilege.” Seeking documents in order to assess claims of privilege over the very documents she seeks…
…stay this action pending completion of any such investigation. Doc.101. In part, Ms. Maxwell needed information concerning any such investigation to assess "the impact on any 5th Amendment privilege." Id. at 2, 4-5. Judge Sweet denied that motion…
…Prof. Dershowitz. More important, the Court would be hard pressed to see how these allegations mean anything close to what Plaintiff asserts or bar the First Amendment right of access. To suggest that Mr. Cernovich is somehow acting for Prof…
…matter. The inquiry could end there, but the other factors for application of collateral estoppel are equally important to assessing both the lack of preclusive effect and the unreliability of the Florida Court’s Order. It is true that there…
…She disingenuously argues that she “executed” her discovery responses. Resp. at 7. She only did so a mere two hours before filing her Response. She asserts she produced all attachments to emails. Resp. at 6-7. She has not…
…or the importance of the discovery in resolving those issues. She simply fails to provide any information by which the Court can assess these factors, and thus should not be permitted to exceed the deposition limit based on her proffer…
…or the importance of the discovery in resolving those issues. She simply fails to provide any information by which the Court can assess these factors, and thus should not be permitted to exceed the deposition limit based on her proffer…
…with an additional two-week period granted to respond to Plaintiff’s First Request for Production of Documents.6 The discovery was thus never stayed. Plaintiff erroneously asserts that that discovery “did not commence in this matter until” February 8…
…much less discuss, Florida law, she has not carried that burden.) Defendant asserts that she can force disclosure of the privileged communications between Ms. Giuffre and her counsel under the “at issue” doctrine. To establish this alleged waiver, Defendant’s…
…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's officer from (B) Information Produced. If information produced in response to a significant expense…
…Request 23: “All manuscripts and/or other writings whether published or unpublished, created in whole or in part by Jane Doe #3 concerning Epstein and any of his agents or associates.” 20 Dershowitz asserts that before this May 11, 2011…
…S.2d 372 (Civ. Ct. 2009): While it is true that an adverse inference may not generally be drawn against a party when a nonparty asserts the privilege (see Access Capital v DeCicco, 302 AD2d 48, 52 [1st Dept 2002…