…foreign or domestic, directly or indirectly held by You, or held on Your behalf or for Your benefit by another individual or entity, including trusts from January 2015 to the Present. DOCUMENT REQUEST NO. 34 Produce all accounts receivable ledgers…
…foreign or domestic, directly or indirectly held by You, or held on Your behalf or for Your benefit by another individual or entity, including trusts from January 2015 to the Present. RESPONSE: Ms. Maxwell objects to this Request on the…
…Boies Schiller (serving here as “Plaintiff’s Counsel”) also represents numerous other accusers in numerous other litigations against Epstein and his Estate. 7 Ms. Giuffre’s Estate may not stand to benefit from further disclosures about Ms. Giuffre, her past…
…to any party’s claim or defense, are not proportional to the needs of the case, and creates a heavy burden on…
…are not relevant to any party’s claim or defense, are not proportional to the needs of the case, and creates …
…decision by the Court to undercut that purpose. Should Does 1 and 2 wish to submit a more thorough explanation for their objection, doing so would be to the benefit of all involved in this process. Third, and relatedly, that …
…whether the party requesting the deposition has had other opportunities to obtain the same information, and whether the burden of a second deposition outweighs its potential benefit.’” Id. (quoting Ganci, 1 Case 1:15-cv-07433-LAP Document 1330…
…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 Rules of Civil Procedure, particularly under the 2015 amendments to Rule…
…Therefore, the Court can have the benefit of whichever format it prefers to work from. Plaintiff’s format includes the specifics of sealed orders and details of the sealed exhibits for ease of the Court’s reference and accordingly is…
…on privilege, he wagered that the consequences from this Court for his deliberate violation of the settlement privilege would not be harsh enough to offset the benefit he received by feed ing fa lse information to the press. On December…
…455 at 2. In the interests of judicial economy, the parties believe it would be appropriate to have the benefit of the Court's rulings on these other issues, review the designated testimony in light of such rulings and then…
…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 Rules of Civil Procedure, particularly under the 2015 amendments to Rule…
…Simply put, she should not be allowed to benefit from her obvious failure to properly disclose Ms. Ransome. Ms. Ransome's Testimonv is ot Cumulative And Has Highly Relevant Evidence Defendant also advances the remarkable argument that it is "unlikely…
…for his deliberate violation of the settlement privilege will not be harsh enough to offset the benefit he received by feeding false Case 1:15-cv-07433-LAP Document 1218-37 Filed 07/15/21 Page 3 of 9 …
…it references J. Doe 1 or 2, so that the Court has the benefit of the “Related Docket #” column listing the related filings. Ms. Maxwell submits that consideration of the motions in chronological order is the most logical, efficient and…
…in resolvingthe issu es,and whetherthe bu rd en orex pense of the proposed d iscovery ou tweighs its likely benefit. Ru le 26(b)(1),Fed .R.C iv.P .D efend ant’s d iscovery requ ests foremploymentand…
…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 discovery is prohibited by the Federal Rules of Civil Procedure, particularly under…
…he had no role in issuance of the statement, he has no benefit in the outcome of this litigation and he played no controlling role in its respect. Similarly, there is not any evidence at all to support an adverse…
…fundamentally unfair to allow Giuffre to continue to press these allegations where she and her attorneys have had the full benefit of discovery already conducted concerning these allegations which is in her possession and which is being withheld Dershowitz and…
…Inc., 285 B.R. 101, 109 (E.D.N.Y. 2002) (quoting United States v. Peoples Benefit Life Ins. Co., 271 F.3d 411, 415 (2d Cir. 2001)). Under Rule 24(b), courts in this Circuit consider the following factors…
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