giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…and she has had no opportunity to previously depose these third-party
witnesses.
Finally, there is no substantial burden involved with deposing seven additional witnesses.
Any assessment of burden must take into account the scope of the underlying case. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…and she has had no oppo1tunity to previously depose these third-paity
witnesses.
Finally, there is no substantial burden involved with deposing seven additional witnesses.
Any assessment of burden must take into account the scope of the underlying case. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.363.13
15 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.13
15 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.263.0
14 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.172.0
28 pg
…and she has had no opportunity to previously depose these third-party
witnesses.
Finally, there is no substantial burden involved with deposing seven additional witnesses.
Any assessment of burden must take into account the scope of the underlying case. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.755.0
75 pg
…by her
13 father, Lion Crest, in which the assets that her father owned
14 were placed. So the daughter is then holding assets for her
15 father as a nominee in this Lion Crest company, and the asset
16 …
giuffre-maxwell
gov.uscourts.nysd.447706.1331.30
19 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.988.0_2
6 pg
…a dozen boxes of material, presumably all of the deposition transcripts,” but then
speculates that the transcripts were “unread” and asserts that “[t]he parties do not know whether
Judge Sweet ever reviewed any of the deposition designations, counter-designations…
giuffre-maxwell
gov.uscourts.nysd.447706.1154.0_5
3 pg
…Plaintiff asserts her
belief that the Court will consider in this current round of unsealing not only whether to
release Doe 1 and 2’s names and identifying information but also the same information for
any Non-Party “whose deadlines…
giuffre-maxwell
gov.uscourts.nysd.447706.1119.0_3
4 pg
…untethered to the facts of this case, and it points to no shortcoming
regarding the already unsealed summary judgment materials. It merely asserts, in conclusory
fashion, that the requested materials “are judicial documents” and that no countervailing interests
justify continued…
giuffre-maxwell
gov.uscourts.nysd.447706.1134.0_5
2 pg
…s arguments, and allow Plaintiff to file these materials as it
has already ordered.
Maxwell asserts that Plaintiff’s proposed redactions do not remove “descriptions of
nonparty conduct to discern the identity of a given non-party.” ECF No. 1129…
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.111.2
5 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.997.0
5 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.140.3
4 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…with
an additional two-week period granted to respond to Plaintiff’s First Request for Production of
Documents.6 The discovery was thus never stayed.
Plaintiff erroneously asserts that that discovery “did not commence in this matter until”
February 8…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…the Federal Rules of Civil Procedure provides
that the court may impose a range of sanctions, including dismissal or judgment by default,
preclusion of evidence, imposition of an adverse inference, or assessment of attorneys' fees and
costs. Fed. R. Civ…
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