…Ms. Giuffre’s confidentiality designation. See McCawley Decl. at Exhibit 1, 1 Notably, it appears that Defendant acquired these materials in April, but held onto them without producing them to Ms. Giuffre until after her Ms. Giuffre’s May 3…
…However, logic would dictate that if the police reports are “relevant,” so, too, is the information contained therein and how it was acquired. For that reason, this Court should grant Ms. Giuffre’s requests Nos .1-3. Defendant states that…
…However, logic would dictate that if the police reports are “relevant,” so, too, is the information contained therein and how it was acquired. For that reason, this Court should grant Ms. Giuffre’s requests Nos .1-3. Defendant states that…
…of this information, Barden specifically added that the source was “entirely” his client – the Defendant: “The content of the statement was entirely based on information I acquired in connection with my role as counsel for Ms. Maxwell.” Id. at 7…
…Dean of Students, Mr . , We requested to speak with ••■■M••• C was re interviewed, as she still was in possession of the rental car that Epstein had acquired for her. ■ stated that Sarah, Epstein's assistant, had called her…
…Font: 12 pt (a) that is or has become publicly known through no fault of the Receiving Party; (b) that is lawfully acquired by or known to the Receiving Party independent of the Producing Party; (c) that was previously produced…
…Dean of Students, Mr . , We requested to speak with ••■■M••• C was re interviewed, as she still was in possession of the rental car that Epstein had acquired for her. ■ stated that Sarah, Epstein's assistant, had called her…
…Dean of Students, Mr . , We requested to speak with ••■■M••• C was re interviewed, as she still was in possession of the rental car that Epstein had acquired for her. ■ stated that Sarah, Epstein's assistant, had called her…
…Defendant should produce the requested documents. If such documents were obtained in contravention of Florida Statutes, it cannot be hidden behind a production of later-acquired police reports. Accordingly, the Court should compel production of these documents. 5 ii…
…by [the party] for the purpose of communicating with their lawyers in confidence, their contents have acquired no special protection from the simple fact of being turned over to an attorney.”); Astra Aktiebolag v. 4 Plaintiff concedes that the items…
…65 L. Ed. 2d 973 (1980)(“Instead of acquiring information about trials by firsthand observation or by word of mouth from those who attended, people now acquire it chiefly through the print and electronic media . . . validat[ing] the media claim…
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