…agreement with her and Epstein that would allow for 7 Epstein to do anything to represent her in this deposition. 8 There's no indemnification agreement. There's no identity of 9 counsel. None of these things apply at all…
…to be masked by the redactions. In certain instances, the released materials include a deposition index which allows a reader to readily compare the redaction with the corresponding page index and identify the non-party’s name. See, e.g.…
…Therefore, Ms. Giuffre is now required to take the deposition of pilot Dave Rodgers to authenticate his pilot logs and the identity of the individuals on various flights. In addition, as the Court knows, this case involves allegations that Ms…
…another purpose, such as proving motive, opportunity, intent, preparation, plan, knowledge, identity, absence of mistake, or lack of accident.”). Indeed, even more specifically than the general provisions of Rule 404(b), Rule 415 makes these other acts admissible, due to…
…another purpose, such as proving motive, opportunity, intent, preparation, plan, knowledge, identity, absence of mistake, or lack of accident.”). Indeed, even more specifically than the general provisions of Rule 404(b), Rule 415 makes these other acts admissible, due to…
…another purpose, such as proving motive, opportunity, intent, preparation, plan, knowledge, identity, absence of mistake, or lack of accident.”). Indeed, even more specifically than the general provisions of Rule 404(b), Rule 415 makes these other acts admissible, due to…
…consensual adult sex" and no need be given. The result is to leave Ms. Giuffre with no way of exploring the identity of these alleged adults, the ages of these alleged adults, and indeed whether they were adults at all…
… . : 1-05-000368 (Continued) the previous houseman left . Rodriguez stated that it was his responsibility to keep the identity of the masseuses private. Mr. Epstein had a massage in the morning and one in the afternoon. Mr. Rodriguez stated he…
…providers and produced some of their records. Essentially, Plaintiff argues that her failure to identify her 1 In her own flagrant attempt to direct attention away from sanctionable litigation tactics, Plaintiff includes in her “Introduction” and her “Conclusion” inaccurate, incomplete…
…28 Therefore, Ms. Giuffre is now required to take the deposition of pilot Dave Rodgers to authenticate his pilot logs and the identity of the individuals on various flights. In addition, as the Court knows, this case involves allegations that…
…consensual adult sex" and no need be given. The result is to leave Ms. Giuffre with no way of exploring the identity of these alleged adults, the ages of these alleged adults, and indeed whether they were adults at all…
…and that both such redactions should be made in a manner to prevent a reader from easily inferring the identity of the individual in question based on the name’s location in the index and the context surrounding the name…
…commenting on, regarding, discussing, showing, describing, reflecting, analyzing or constituting. 9. “Identify” means, with respect to any “person,” or any reference to the “identity” of any “person,” to provide the name, home address, telephone number, business name, business address, business…
…Ms. Giuffre gave to Defendants in her interrogatories (Mtn. at 3), but then states that “Plaintiff failed therein to identify any treatment providers prior to the alleged defamation, despite the Court’s order concerning 1999- 2015.” (Mtn. at 4). This…
…nature, custody, condition, and location of any documents or other tangible things and the identity and location of persons who know of any discoverable matter. For good cause, the court may order discovery of any matter relevant to the subject…
…of HealthCare Information Date Plaintiff’s Statement Truth Sources March 16 Refusal to identify any health Privilege waived by Plaintiff when Plaintiff’s Responses & care providers or records because suing for $30 millio…
…Court’s instructions during the March 31, 2020 telephone conference, to identify the first five motions for the unsealing process. The Original Parties have met and conferred multiple times to propose five motions pertaining to J. Doe 1 and J…
…and requests that the Court unseal and make public and unredacted any and all documents that identify the men who abused the girls trafficked by Jeffrey Epstein and Defendant Maxwell (“the Epstein Client List”). Sealing those documents violates the rights…
…15 Civ. 7433 (LAP) Dear Judge Preska: Paragraph 1 of the Court’s October 28 Order (Doc.998) required the parties to identify motions decided by the Court and related papers that were sealed or redacted (“Sealed Materials”). Paragraphs 3…
…accessible. Given that you have had this information all along, the protestations that you have been unable to timely identify Plaintiff’s treatment providers or produce records is demonstrably inaccurate. In light of your representations to the Court regarding the…