…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…
…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…
…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…
…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…
…award Ms. Maxwell reasonable attorney fees and costs incurred in bringing this Motion. I. Plaintiff’s interrogatory responses are deficient. Interrogatory No. 5. Identify each Communication that You or Your Attorneys have had with any author, reporter, correspondent, columnist, writer…
…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…
…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…
…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, …
…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…
…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…
…made calls and interviewed particular sources, techniques for the reporters’ investigation, and the backgrounds of the co- authors and editorial staff). 3 See generally Beth Winegarner, 5 tips for journalists who want to do a better job of cultivating sources…
…made calls and interviewed particular sources, techniques for the reporters’ investigation, and the backgrounds of the co- authors and editorial staff). 3 See generally Beth Winegarner, 5 tips for journalists who want to do a better job of cultivating sources…
…made calls and interviewed particular sources, techniques for the reporters’ investigation, and the backgrounds of the co- authors and editorial staff). 3 See generally Beth Winegarner, 5 tips for journalists who want to do a better job of cultivating sources…
…is a gentleman 17 by the name of Stan Pottinger. He is a lawyer of some renown. 18 He is also an author of best-selling books. He is listed quite 19 frequently on plaintiff's privilege log as being…
…l\~in11. i~ prnJm·tion
…is a gentleman 17 by the name of Stan Pottinger. He is a lawyer of some renown. 18 He is also an author of best-selling books. He is listed quite 19 frequently on plaintiff's privilege log as being…
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