giuffre-maxwell
gov.uscourts.nysd.447706.57.3
39 pg
…r. 32.7 – Control of Major Hazard Regulations
1999.
This was an application by the third party (TAV) for specific disclosure of
documents over which the defendants had asserted litigation privilege. E
The proceedings arose out of the explosion and…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.33
12 pg
…07/15/21 Page 2 of 12
Importantly, Defendant has never denied using an email account for communication from
1999-2009, and the facts and circumstances show that it is exceedingly unlikely that Defendant
did not use an email account…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 pg
…nor produce documents from it.
Importantly, Defendant has never denied using an email account for communication from
1999-2009, and the facts and circumstances show that it is exceedingly unlikely that Defendant
did not use an email account to…
giuffre-maxwell
gov.uscourts.nysd.447706.468.0
12 pg
…nor produce documents from it.
Importantly, Defendant has never denied using an email account for communication from
1999-2009, and the facts and circumstances show that it is exceedingly unlikely that Defendant
did not use an email account to…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.8
12 pg
…LAP Document 1320-8 Filed 01/03/24 Page 10 of 12
subpoena to the witness alone satisfies Rule 45. See Cordius Trust v.. Kummerfeld, 1999 U.S.
Dist. Lexis 19980, *5–*6 (S.D.N.Y.1999); Ultradent Products…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.17
25 pg
…1, in particular the definition of the
“Relevant Period” to include July 1999 to the present, on the grounds that it is overly broad and
unduly burdensome and calls for the production of documents that are irrelevant to this action…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…does not seek and does not require the production of multiple copies of
identical Documents.
9. Unless otherwise specified, the time frame of this request is from 1999 to present.
I 0. This Request is deemed to be continuing. If…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…investigators, from the period 1999-present.
RESPONSE:
In addition to the Preliminary Statement and General Objections, Ransome objects to this
request in that she is a non-party and this requests seeks fundamentally privileged communications
between a non-party and…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…investigators, from the period 1999-present.
RESPONSE:
In addition to the Preliminary Statement and General Objections, Ransome objects to this
request in that she is a non-party and this requests seeks fundamentally privileged communications
between a non-party and…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…investigators, from the period 1999-present.
RESPONSE:
In addition to the Preliminary Statement and General Objections, Ransome objects to this
request in that she is a non-party and this requests seeks fundamentally privileged communications
between a non-party and…
giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
…INSTRUCTIONS
1. Unless indicated otherwise, the “Relevant Period” for this Request is from 1999
to the present. A Document should be considered to be within the relevant time frame if it refers
or relates to communications, meetings or other events…
giuffre-maxwell
1320-8
12 pg
…LAP Document 1320-8 Filed 01/03/24 Page 10 of 12
subpoena to the witness alone satisfies Rule 45. See Cordius Trust v.. Kummerfeld, 1999 U.S.
Dist. Lexis 19980, *5–*6 (S.D.N.Y.1999); Ultradent Products…
giuffre-maxwell
1320-17
25 pg
…1, in particular the definition of the
“Relevant Period” to include July 1999 to the present, on the grounds that it is overly broad and
unduly burdensome and calls for the production of documents that are irrelevant to this action…
giuffre-maxwell
gov.uscourts.nysd.447706.160.0
12 pg
…07433-LAP Document 160 Filed 05/25/16 Page 10 of 12
subpoena to the witness alone satisfies Rule 45. See Cordius Trust v.. Kummerfeld, 1999 U.S.
Dist. Lexis 19980, *5–*6 (S.D.N.Y.1999); Ultradent Products…
giuffre-maxwell
gov.uscourts.nysd.447706.370.0
17 pg
…198
F.3d 317, 322-23 (2nd Cir. 1999) (“This Court has recognized the existence of a constitutionally
protected interest in the confidentiality of personal financial information.”) (quoting Barry v.
City of New York, 712 F.2d 1554, 1558–59 …
giuffre-maxwell
gov.uscourts.nysd.447706.1219.19
17 pg
…198
F.3d 317, 322-23 (2nd Cir. 1999) (“This Court has recognized the existence of a constitutionally
protected interest in the confidentiality of personal financial information.”) (quoting Barry v.
City of New York, 712 F.2d 1554, 1558–59 …
giuffre-maxwell
gov.uscourts.nysd.447706.371.2
18 pg
…1, in particular the definition of the
“Relevant Period” to include July 1999 to the present, on the grounds that it is overly broad and
unduly burdensome and calls for the production of documents that are irrelevant to this action…