…privilege. It is well settled that waiver may be imposed when the privilege-holder has attempted to use the privilege as both ‘sword’ and ‘shield.’ Granite Partners, L.P. v. Bear Stearns & Co. Inc., 184 F.R.D. 49, 54…
…is on the Trilateral Commission, the Council on Foreign Relations, the New York Academy of Sciences and the Institute of International Education. His current fan club extends to [Bear Stearns CEO James] Cayne, Henry Rosovsky, the former dean of Harvard…
…evidence to be discoverable. Relevance is still to be “construed broadly to encompass any matter that bears on, or that reasonably could lead to other matter that could bear on” any party's claim or defense. State Farm Mut. Auto…
…Maxwell anticipates more extensive briefing on this issue in support of Mr. Epstein’s Motion to Quash, a few facts bear mentioning here: x Ms. Maxwell was the employee of Mr. Epstein --in the 1990s -- not the other way around…
…31 Indeed, the documents in question could hardly “confirm his absolute innocence.” DE - 364 at 1. The documents do not directly bear on Ms. Giuffre’s sworn and detailed statements about how Dershowitz sexually abused her, statements that are corroborated…
…that are irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Communications with the media regarding cases that bear no relation to the subject matter of this case, from decades in the past…
…LAP Document 1078-5 Filed 07/29/20 Page 91 of 161 'The recollections of the victims bear striking resemblances that corroborate each other and provide compelling proof of the defendant's active participation in a disturbing scheme to groom…
…Maxwell anticipates more extensive briefing on this issue in support of Mr. Epstein’s Motion to Quash, a few facts bear mentioning here: Ms. Maxwell was the employee of Mr. Epstein --in the 1990s -- not the other way around…
…to me, and my siblings, and our kids and that was pop's love, like a big bear hug on your heart kind of love. His unique sense of humor could be a weapon and a salve. M. CUOMO: Christopher…
…and how much, all bear signifcant relevance to her claims that she was given financial incentives by Epstein and Maxwell in exchange for sexual compliance. The subpoena is narrowly tailored to (a) money directly from Epstein or his associates, or …
…Pentateuch and the Book of Exodus, and its command as clear as the Decalogue: "Thou shall not bear false witness against thy neighbor." The personal interest in one's own good name and reputation surpasses economics, business practices or money…
…and how much, all bear signifcant relevance to her claims that she was given financial incentives by Epstein and Maxwell in exchange for sexual compliance. The subpoena is narrowly tailored to (a) money directly from Epstein or his associates, or …
…by time period, though Defendant need not answer questions that relate to none of these subjects or that is clearly not relevant, such as sexual activity of third-parties who bear no knowledge or relation to the key events , individuals…
…Austrich, Tony Figueroa, Sky Roberts, Brittany Henderson, and Juan Alessi,” which “do not bear confidential designations” and which were unsealed by the Court of Appeals’ unsealing of the Maxwell summary judgment record. (See dkt. no. 153 in 19 Civ. 3377…
…calculated to lead to the discovery of admissible evidence. Communications with the media regarding cases that bear no relation to the subject matter of this case, from decades in the past, are facially invalid and not calculated to lead to…
…and Maxwell must make a “clear showing” of all of the elements to overcome the protection for non- 1 Defined, capitalized terms bear the same meanings as in Churcher’s Memorandum of Law in Support of the Motion (Dkt. No…
…Maxwell anticipates more extensive briefing on this issue in support of Mr. Epstein’s Motion to Quash, a few facts bear mentioning here: x Ms. Maxwell was the employee of Mr. Epstein --in the 1990s -- not the other way around…
…31 Indeed, the documents in question could hardly “confirm his absolute innocence.” DE 364 at 1. The documents do not directly bear on Ms. Giuffre’s sworn and detailed statements about how Dershowitz sexually abused her, statements that are corroborated…
…JDA has no relevance whatsoever to Plaintiff’s single claim for defamation. For example, it would not bear on the truthfulness of Ms. Maxwell’s denial of Plaintiff’s claim of sexual misconduct; it would not bear on whether Ms…
…Today is September 8, 2009. 7 around 19 -- please bear with the dates because I 8 The time is 12 minutes after 10:00 in the morning. 8 trying -- 9 This is the videotaped deposition of Juan 9 Q. Sure. …
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