…information, Churcher is the only source of the information sought. She is the only person who can provide the following information and documents: x The 24 page fabricated diary, and testimony on when and why it was created5 x Notes…
…particular documents are being withheld, let alone other relevant information about the withheld documents (e.g., date, author, subject matter). Because Dershowitz is not in a position to tailor his arguments to specific assertions of privilege, Dershowitz addresses the asserted…
…the issues; documents that are not relevant to any party’s claim or defense; and documents that are not proportional to the needs of the case. Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such…
…f. the disposition of any case associated with any such Communication, irrespective of whether the matter was sealed, expunged or later dismissed. 5. Identify each Communication that You or Your Attorneys have had with any author, reporter, correspondent, columnist, writer…
…the issues; documents that are not relevant to any party’s claim or defense; and documents that are not proportional to the needs of the case. Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such…
…to any party’s claim or defense; and documents that are not proportional to the needs of the case. Such requests would create a heavy burden on Ms. Giuffre that outweighs any benefit. Such discovery is prohibited by the Federal…
…the issues; documents that are not relevant to any party’s claim or defense; and documents that are not proportional to the needs of the case. Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such…
…person responding need not provide discovery of electronically stored information (2) Command to Produce Materials or Permit ln5pection. from sources that the person identifies as not reasonably accessible because (A) Appear…
…the issues; documents that are not relevant to any party’s claim or defense; and documents that are not proportional to the needs of the case. Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such…
…the issues; documents that are not relevant to any party’s claim or defense; and documents that are not proportional to the needs of the case. Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such…
…Civ. P. 44.1 (permitting Court to consider “any relevant material or source” to determine issue of foreign law). 4 Without waiver of the choice-of-law issue, Ms. Maxwell submits that the privilege also applies to her communications…
…electronically stored information, or tangihle things, or to from sources that the person identifies as not reasonably accessible because p~rmit the inspection of premises, need not appear in person at the place of of undue burden or cost. On motion…
…tangible made, the court may nonelheless order discovcry from such sources if Ihe lhings Of to permit inspection may serve on the party or attorney designated requesting party shows good cause, considering the limitations of Rule in the subpoena a…
…the issues; documents that are not relevant to any party’s claim or defense; and documents that are not proportional to the needs of the case. Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such…
…the issues; documents that are not relevant to any party’s claim or defense; and documents that are not proportional to the needs of the case. Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such…
…electronically stored information, or tangihle things, or to from sources that the person identifies as not reasonably accessible because p~rmit the inspection of premises, need not appear in person at the place of of undue burden or cost. On motion…
…the issues; documents that are not relevant to any party’s claim or defense; and documents that are not proportional to the needs of the case. Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such…
…it is well-recognized that the non-moving party faced with a summary judgment motion supported by appropriate proof may not rely on bare, conclusory assertions found in the pleadings to create an issue and thus avoid summary judgment. Instead…
…04/12/17 Page 15 of 94 15 H3u1giua 1 redacted, we have no idea who the author of the report is. 2 THE COURT: What's the provenance of this report that 3 we're talking about? 4 MS…
…04/12/17 Page 15 of 94 15 H3u1giua 1 redacted, we have no idea who the author of the report is. 2 THE COURT: What's the provenance of this report that 3 we're talking about? 4 MS…