…which Ms. Maxwell is a target. First, Plaintiff claimed that the documents were protected by a non-existent “investigative privilege.” When Ms. Maxwell demonstrated that the “investigative privilege” does not exist, Plaintiff threw up the inapplicable “public interest” privilege, the…
…so. 2 Case 1:15-cv-07433-LAP Document 1330-17 Filed 01/05/24 Page 4 of 12 The Motion is untimely and no special circumstance exists, nor have any been claimed, requiring denial of the motion. B…
…evidentiary hearing might be required, as contemplated under the Protocol. At this point, the foregoing serves only to further illustrate that the non-parties are not the source of the claimed delay or inefficiencies. Rather, any execution issues are directly…