…would either enable or require her to do so.” Id. Plaintiff never responded. She also has not explained when or how Ms. Maxwell “acknowledged” her “plans to call Mr. Gow for testimony at trial,” nor why that is relevant to…
…BASED ON ASSERTIONS OF ATTORNEY-CLIENT PRIVILEGE. In her motion, Ms. Giuffre explained that she sought production of communications between Defendant and her attorney, Philip Barden, which “Defendant listed on her privilege log.” Plaintiff’s Motion to Compel All Work…
…try to have his client , Jeffrey Epstein available to be interviewed. I explained I would be interested in conducting an interview with his client as well as other employees that are employed within the house. Atty. Fronstin advised he would …
…s needs for discovery, the Court should enter a protective order against further discovery (DE 640) and deny Defendant’s Combined Motion to Compel1 (DE 655). As explained in Non-Party Ransome’s Motion for Protective Order, Defendant should not …
…or Independent of the Protective Order Ms. Giuffre explained in detail why her application to the Court is timely filed under the Protective Order [DE 62], and will not burden the Court with a recitation of such details and arguments…
…izing that the First Amendment reporter's privilege also applies to non-confidential newsgathering information, the Second Circuit has explained that the reporter's privilege reflects "broader concerns" beyond the confidentiality of a r eporter 's sources, noting that the …
…person's reputation. As the Fourth DCA has explained in upholding a punitive damages award in a defamation case: Florida's unusually high protection of personal reputation derives from the common consent of humankind and has ancient roots. It is…
…and foundation. 5 Q. You can answer. 6 A. I just explained. 7 A. I spent the entire time talking to 8 Virginia's mother outside the house so the 9 answer to the question is no. 10 Q. No…
…not the case. Guests having massages did not have massages in Mr. Epstein’s private bedroom suite. This area was private and off- limits to guests, which I explained to the lawyers during my deposition. Id. at ¶¶ 9-10. 40…
…try to have his client , Jeffrey Epstein available to be interviewed. I explained I would be interested in conducting an interview with his client as well as other employees that are employed within the house. Atty. Fronstin advised he would …
…11, 2016) (“The [advocate- witness] rule does not bar counsel's participation in pre-trial proceedings.”). As this Court has previously explained, “[t]he concerns underlying [the advocate-witness rule] arise out of an attorney’s presence at trial. Allowing…
… She explained that she lived in Palm Beach 25 and didn't want butlers because they're too stuffy. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 10 of 179 Page…
…did not rely on them in adjudicating a motion, this was legal error. As explained above, the proper inquiry is whether the documents are relevant to the performance of the judicial function, not whether they were relied upon.36 Indeed…
…alia, motions to compel testimony, to quash trial subpoena, and to exclude certain deposition testimony.” Id. As the court explained, All such motions, at least on their face, call upon the court to exercise its Article III powers. Moreover, erroneous…
…emotional distress damages. 1. The information withheld is critically important As fully explained in the Motion to Compel Rule 26(a) disclosures, to date Plaintiff still has not provided an actual computation of the physical and emotional distress damages she …
…Now the question is whether he thinks they are fair game for the sexual exploits of his powerful associates and himself. Dershowitz and the UK's Prince Andrew were ~
…if possible, this Motion for Clarification be set for hearing on an expedited basis in order to be heard at the hearing already scheduled on other related discovery issues on April 21, 2016 at 11:00 am. 1 Case…
…as a government actor, does not have a compelling need for the materials because “the Government as investigator has awesome powers” which “render unnecessary its exploitation of the fruits of private litigation.” See Martindell, 594 F.2d at 296 (citations…
…including one named "Virginia." Id. at 21. It is anticipated that he will testify consistently with that previous testimony. 3 As explained above, as of today, Defendant's coW1sel sent an email refusing to attend this deposition set for Tuesday…
…phone number. There was no privilege asserted. 15 We asked for her financial information in our opening 16 papers. We explained the relevance of that financial 17 information. There was no response to that relevance argument, 18 your Honor, so…