Found 69 results for “assets” in 458ms

gov.uscourts.nysd.447706.1219.30.pdf PDF

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…

gov.uscourts.nysd.447706.1307.4.pdf PDF

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…

gov.uscourts.nysd.447706.1295.11.pdf PDF

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…

gov.uscourts.nysd.447706.1137.12_2.pdf PDF

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…

gov.uscourts.nysd.447706.363.13.pdf PDF

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…

gov.uscourts.nysd.447706.1218.13.pdf PDF

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…

gov.uscourts.nysd.447706.263.0.pdf PDF

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…

gov.uscourts.nysd.447706.172.0.pdf PDF

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…

gov.uscourts.nysd.447706.755.0.pdf PDF

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 …

gov.uscourts.nysd.447706.1331.30.pdf PDF

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…

gov.uscourts.nysd.447706.988.0_2.pdf PDF

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…

gov.uscourts.nysd.447706.1154.0_5.pdf PDF

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…

gov.uscourts.nysd.447706.1119.0_3.pdf PDF

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…

gov.uscourts.nysd.447706.1134.0_5.pdf PDF

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…

gov.uscourts.nysd.447706.1224.0.pdf PDF

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…

gov.uscourts.nysd.447706.111.2.pdf PDF

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…

gov.uscourts.nysd.447706.997.0.pdf PDF

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…

gov.uscourts.nysd.447706.140.3.pdf PDF

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…

gov.uscourts.nysd.447706.1320.28.pdf PDF

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…

gov.uscourts.nysd.447706.1332.1.pdf PDF

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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