…particularly in light of Ms. Giuffre’s punitive damages claim as well as press reports suggesting that the Defendant may be selling her assets in New York and transferring the money outside the jurisdiction. Accordingly, Defendant’s motion for a…
…particularly in light of Ms. Giuffre’s punitive damages claim as well as press reports suggesting that the Defendant may be selling her assets in New York and transferring the money outside the jurisdiction. Accordingly, Defendant’s motion for a…
…permissible to the limited issue of punitive damages, Plaintiff changes tactics claiming the discovery also relates to 1) Ms. Maxwell’s alleged potential sale of assets in this country and 2) Ms. Maxwell’s alleged financial dependence on Mr. Epstein…
…protected, will enable the parties to assess the claim. An “unjustified failure to list privileged documents on the required log of withheld documents in a timely and proper manner operates as a waiver of any applicable privilege,” OneBeacon Ins. Co…
…June 8, 2012), http://www.poynter.org/2012/5-tips-for-journalists-who-want-to-do-a-better-job-of-cultivating- sources/176219/ (“Sources are one of a reporter’s biggest assets. If you cover a regular beat, you’ll…
…June 8, 2012), http://www.poynter.org/2012/5-tips-for-journalists-who-want-to-do-a-better-job-of-cultivating- sources/176219/ (“Sources are one of a reporter’s biggest assets. If you cover a regular beat, you’ll…
…June 8, 2012), http://www.poynter.org/2012/5-tips-for-journalists-who-want-to-do-a-better-job-of-cultivating- sources/176219/ (“Sources are one of a reporter’s biggest assets. If you cover a regular beat, you’ll…
…wealth for presentation on the amount of punitive damages sought should be limited to a statement of defendant’s net worth; there is no need for plaintiff to explore the details of a defendant’s assets and liabilities. Rupert v…
…wealth for presentation on the amount of punitive damages sought should be limited to a statement of defendant’s net worth; there is no need for plaintiff to explore the details of a defendant’s assets and liabilities. Rupert v…
…protected, will enable the parties to assess the claim. An “unjustified failure to list privileged documents on the required log of withheld documents in a timely and proper manner operates as a waiver of any applicable privilege,” OneBeacon Ins. Co…
…moves for a brief adjournment of the April 13 hearing until April 21, 2016, when Ms. Maxwell’s Motion to Compel will be heard by this Court. As grounds she asserts as follows: 1. On April 5, 2016, Paul A…
…Appear Pro Hac Vice in this Matter (Doc. #112 - 115). As further grounds, she asserts as follows: INTRODUCTION On April 21, 2016, the Court conducted a hearing on the Motions of Messrs. Cassell and Edwards to appear pro hac vice…
…for Court intervention. The parties have been unable to reach resolution on these issues. INTRODUCTION Plaintiff asserts improper claims of attorney-client and work product privilege in her privilege log and wrongfully withheld documents based on these unsubstantiated claims. See …
…current assertion that “Doe 171 has not received Doc. 211” demonstrably false. Doe 171 also asserts that “Doe 171 has never been publicly associated with the scandalous and intimate activities described in most or all of the Confidential Records.” Id…
…Maxwell asserts that she will need time to review each Non-Party Objection to decide whether or not to submit a Party Objection under section 2(e) of the Protocol, but Maxwell is not required to file a separate Party…
…Civ. P., of the Rugged Thunderbolt External Hard Drive (“Rugged TBT Drive”) Plaintiff asserts that he purchased and which is at the core of this putative consumer class action. See DE 40. The parties have confirmed that Plaintiff’s deposition…
…the Ransome deposition, the Emails should be disclosed at the same time to allow the public to understand the full context of Ms. Ransome’s testimony, and to assess the credibility (or lack thereof) of Ms. Ransome. Ms. Giuffre should…
…Plaintiff cites for that bald proposition the following language (quoted here from Plaintiff’s brief in its entirety): “‘Insofar as the District Court held that these materials are not 1 The Plaintiff also asserts that our “arguments are unnecessary,” id…
…at issue; rather, an in camera assessment of the disputed documents was deemed necessary to weigh whether the particular requested documents are shielded by a public-interest privilege against disclosure of confidential communications. 4 The public interest privilege applied, in…
…herself has waived the privilege by making repeated and voluntary statements about her allegations about being a “sex 2 Plaintiffs filed a privilege log in this lawsuit that broadly and only categorically asserts the attorney-client and work product privileges…
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