…here, should this Court find that any duty attaches, which it does not, as explained above. 9 the straightforward assertion that the opposing party has failed to produce requested information.” Id. at 293 (quoting Orbit One Commc’ns. v. Numerex…
…But the degree of indignation at allegations is not a sound basis for allowing intervention. As the Court previously explained, it “cannot permit anyone slighted by allegations in court pleadings to intervene and conduct mini-trials to vindicate their reputation…
…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 …
…And, as this Court has already explained, taking the deposition or a newly-discovered witness cures any prejudice: " [t]his and other courts have adopted the taking of depositions as an appropriate mechanism to address late-disclosed witnesses." NJBJA Ins…
…Giuffre and others; and Defendant continued to communicate with convicted sex offender Jeffrey Epstein until at least 2015. As explained in Ms. Giuffre’s Motion to Compel, the abuse underlying this case started in or around 6 Defendant contends she…
…of 26 1. The Qualified “Self Defense” Privilege Does Not Protect The Publication Of Deliberately False Statements. As will be explained fully in the Opposition to Maxwell’s Motion to Dismiss, the “self- defense” privilege does not protect the Defendant…
…with information about the sexual assault), it is unclear what interest could be served by making the Rule 26 disclosures non-confidential. Defendant has not explained why the disclosures should be public. Moreover, Defendant cannot show good cause to publicize…
…6 MS. MENNINGER: Plaintiff had it, plaintiff provided 7 it to us in discovery, plaintiff has not explained where it 8 came from. 9 THE COURT: End of story. 10 MS. MENNINGER: Right. The author is redacted, your 11 Honor…
…Through lawyers1, Ms. Giuffre explained what Epstein and Defendant had done to her, prompting a broadside of attacks earlier this year from the 1 Ms. Giuffre is represented in the CVRA case by a former Federal Judge for the District…
…in this defamation matter . . . .”) (emphasis added); Doe Obj. at 3 (“The government has sufficient investigatory powers that it is unnecessary for it to ‘exploit[] . . . the fruits of private investigation.’”) (quoting Martindell, 594 F.2d at 296 (alterations in Objection)). This…
…entitled to much weight here.” Tr. of July 23 Hearing, at 5. The Court said Ms. Maxwell had not explained how the sealed material could inappropriately influence potential witnesses or victims. Id. The effect of Ms. Maxwell’s indictment, arrest…
…biases; otherwise the Daily News could not publish positive stories about the Mets. As the Second Circuit explained, “consideration of the [journalist’s] ultimate interest in the case should not affect the weight of the presumption [of access].” Lugosch v…
…first place. That is not the issue. Plaintiff does not limit her Declarations and affidavits to “facts” – she specifically discusses what she has “told” her attorneys, what her attorney “explained” to her, and her “direction” to counsel. Menninger Decl., Ex…
…She has further explained that the recruitment of females through the offer of some legitimate position was the typical way in which Defendant and Epstein lured unsuspecting females to the house before converting the relationship into a sexual 7 …
…6 MS. MENNINGER: Plaintiff had it, plaintiff provided 7 it to us in discovery, plaintiff has not explained where it 8 came from. 9 THE COURT: End of story. 10 MS. MENNINGER: Right. The author is redacted, your 11 Honor…
…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 counsel sent an email refusing to attend this deposition set for Tuesday…
…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 …
…Defendant's participation in massages with Epstein is a central part of this case. Ms. Giuffre has explained that during her first sexual encounter with Jeffrey Epstein, it was Defendant who provided instruction on how to do it and how…
…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…
…response to Dershowitz’s intervention motion. McCawley Decl., Exhibit 3, Response to Motion to Intervene.3 The response explained that the allegations against Dershowitz were relevant to at least eight separate issues in the CVRA case. Id. at 18-26…