…For example, Maxwell identifies Dkt. 370, which involves a motion for a protective order regarding her own personal financial information that could be presented at trial for the purpose of plaintiff’s punitive damage claim. Dkt. 991 at 5; see…
…18 In addition, with regard to the financial information, 19 your Honor has directed the defense to produce all of the 20 financial information but just shortly before trial. So we 21 haven't had an opportunity to look at…
…worked for or been in control of Ms. Maxwell. Ms. Maxwell and Mr. Epstein have had no financial, professional or employment relationship in more than a decade, many years before 2015 when the purportedly defamatory statement was published. Ms…
…19 Page 3 of 6 Honorable Loretta A. Preska November 12, 2019 Page 3 F.T.C. v. Standard Financial Management Corp., 830 F.2d 404 (1st Cir. 1987). In F.T.C. a district court relied upon financial records…
…is not targeted to any person, event, or job. The request could be interpreted in many ways and could include any financial, banking or accounting record compiled over a 17-year time frame. As such, the request fails and Ms…
…copied on the email. The pre-litigation privilege is intended to protect attorneys from defamations claims "so that those discharging a public function may speak freely to zealously represent their client s without fear of reprisal or financial hazard." Id…
…389-4) have no relevance to Judge Sweet’s ruling on the Motion for Protective Order regarding the Personal Financial Information of the Defendant (DE 4 Case 1:15-cv-07433-LAP Document 1215 Filed 02/19/21 Page…
…assertions about me, other examples of her lack of credibility are relevant. 53. In the first place, Ms. Giuffre has been demonstrated to have made up wildly implausible tales for financial gain. In 2011, for example, Ms. Giuffre was interviewed…
…Such documents are plainly protected by attorney-client privilege. The privileged character of these communications is not negated by Dershowitz's claimed need to probe her and her lawyers' financial motivations. The Florida District Court of appeal has plainly held…
…639 (2d Cir. 1962) (“Insofar as the papers include pre-existing documents and financial records not prepared by [the party] for the purpose of communicating with their lawyers in confidence, their contents have acquired no special protection from the simple…
…assets for her 15 father as a nominee in this Lion Crest company, and the asset 16 happened to be a horse in that particular case. 17 There were significant financial ties between Edith, 18 the daughter, and her father…
…There, the plaintiffs sued their financial advisor over the alleged failure to accurately value a company—“L&H”—before it merged with the plaintiffs’ company. The Wall Street Journal had published stories questioning the valuation of L&H that same…
…order. The only document that Ms. Maxwell claims actually falls within this exception is Document 370, which is a motion for a protective order regarding Ms. Maxwell’s personal financial information. Even with respect to Document 370, however, only Ms…
…The financial and other terms associated with the settlement are confidential. ARGUMENT The Court should not permit the Defendant to use at trial in this case excerpts from Dershowitz’s deposition in the Florida state defamation case involving Edwards and…
…The defense intends to show that Plaintiff for financial and other improper reasons manufactured her allegations of “sex trafficking” and created from whole cloth her alleged $30 million in noneconomic damages from “defamation.” Some of the most relevant and material…
…at 52 (noting that under the common law, a showing of bias by extrinsic evidence was always permitted). The discovery sought concerning Ms. Ransome’s financial information, employment, the nature of her engagement with counsel (including the financial structure of…
…Supp. 374, 376 (D. Colo. 1995). Regarding injury, plaintiffs must prove special damages—meaning economic or financial loss—unless the defamation falls within a category of defamation per se. Kforce, Inc., 288 F. Supp.2d at 516; Thai v. Cayre…
…reasonable trier of fact could find that it would support that claim or defense.” Id. citing Residential Funding Corp. v. DeGeorge Financial Corp., 306 F.3d 99, 108 (2d Cir. 2002). An adverse inference is appropriate regarding the documents that…
…personal, political, and financial gain, as well as to obtain potential blackmail information. One such powerful individual that Epstein forced then-minor Jane Doe #3 to have sexual relations with was former Harvard Law Professor Alan Dershowitz, a close friend…