giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
…considered to be within the relevant time frame if it refers
or relates to communications, meetings or other events or documents that occurred or were
created within that time frame, regardless of the date of creation of the responsive Document.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.28
24 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.32
27 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.223.1
14 pg
…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…
giuffre-maxwell
1320-32
27 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.0
16 pg
…Parties will be reluctant to participate in
this process if their objection will itself become publicized and also believes that despite best
redaction efforts and pseudonym efforts, any objections may reveal the identity of its author.
For those reasons, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.503.0
21 pg
…the
backgrounds of . co-authors and the [publication's]
editorial staff, and whether [the author] consulted with any
experts or other sources in the course of the investigation-all
inquiries into the newsgathering process protected by the Shield
Law." Baker, …
giuffre-maxwell
gov.uscourts.nysd.447706.552.0
2 pg
…Motion to Intervene and
Unseal, filed herewith.
3. Among other professions and hobbies, I am a lawyer, author, documentary
filmmaker, author, and host of the Mike Cernovich Podcast.
4. My broadcasts on Periscope have over 63,000 subscribers and 13…
giuffre-maxwell
gov.uscourts.nysd.447706.881.0
8 pg
…
Anyone who is going to give greater weight to the testimony of someone who is wealthy?
Famous? A professor? An Author? A member of the Royal family? A foreigner?
SEXUAL ASSAULT
Has anyone been accused of being involved…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.21
11 pg
…in any way. Statements or opinions in
this e-mail or any attachment are those of the author and are not
necessarily agreed or authorised by News Corp UK & Ireland Limited
or any member of its group. News Corp UK…
giuffre-maxwell
gov.uscourts.nysd.447706.179.0
22 pg
…Antitrust
Litigation, the Court found the privilege log adequate because it “contains information
concerning the date, type of document, author, addressees, a short description of each document
and the privilege or immunity asserted with respect to each. Submissions by the…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.9
21 pg
…logged as privileged are
improperly withheld other than the fact that one member of
12
Case 1:15-cv-07433-LAP Document 1327-9 Filed 01/05/24 Page 14 of 21
Plaintiff's legal team is an author …
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…considered to be within the relevant time frame if it
refers or relates to communications, meetings or other events or documents that occurred or were
created within that time frame, regardless of the date of creation of the responsive Document.
…
giuffre-maxwell
gov.uscourts.nysd.447706.42.0
7 pg
…a
privilege log entry. Local Civil Rule 26.2 requires that for written communications, a
privilege log should include the author of the document, the addressees of the document,
and any other recipients and “where not apparent, the relationship of…
giuffre-maxwell
gov.uscourts.nysd.447706.155.0
15 pg
…384, 391 (S.D.N.Y. 2015).
b. Work Product Privilege
The work-product privilege protects documents created by counsel or per counsel's
directive, in anticipation of litigation. See In re Grand Jury Subpoenas Dated March 19, 2002 &
August…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.29
24 pg
…considered to be within the relevant time frame if it refers or
relates to communications, meetings or other events or documents that occurred or were created
within that time frame, regardless of the date of creation of the responsive Document.
…
giuffre-maxwell
gov.uscourts.nysd.447706.25.0
13 pg
…as Vidal contends, that Buckley’s intent here was one of
‘poisoning and closing the available publishing markets of defendant as an author and essayist,
and so ruining him economically.’”). The privilege therefore applies so as to protect Ms.
Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.9
21 pg
…pages
on June 1, 2016.
II. Applicable Standards
Rule 26 "create[s] many options for the district judge .
[to] manage the discovery process to facilitate prompt and
efficient resolution of the lawsuit." Crawford-El v. Britton,
523 U.S. 574…
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