gov.uscourts.nysd.447706.156.2.pdf PDF
…05/20/16 Page 1 of 4 EXHIBIT B Case 1:15-cv-07433-LAP Document 156-2 Filed 05/20/16 Page 2 of 4 Media Advice Communications Log Email Sent …
Found 22 results
for “communication”
in 218ms
gov.uscourts.nysd.447706.1330.23.pdf PDF
…several important documents, because Defendant has not offered any substantial countervailing consideration, the Court should allow Ms. Giuffre to question Defendant in a deposition about these late produced communications. I. INTRODUCTION As the Court is well aware, Ms. Giuffre has…
gov.uscourts.nysd.447706.1330.17.pdf PDF
…subjects covered by the emails. Moreover, despite having access to other email communications that are similar in nature and substance to the two email communications Plaintiff now claims are “key” documents, Plaintiff elected to not examine Ms. Maxwell on those …
gov.uscourts.nysd.447706.1330.16.pdf PDF
…that she has 1 Case 1:15-cv-07433-LAP Document 1330-16 Filed 01/05/24 Page 4 of 17 searched all accounts that she can access. Had Plaintiff bothered to follow up on this alleged communication, Ms…
gov.uscourts.nysd.447706.1330.19.pdf PDF
…in that statement? 7 MR. PAGLIUCA: I'm going to object 8 and instruct you to the extent this 9 calls for any privileged communications 10 between yourself and Mr. Barden or 11 another lawyer representing you, we're 12…
gov.uscourts.nysd.447706.1330.8.pdf PDF
…of discovery, and after Defendant’s second deposition was taken, Defendant produced two critical documents which were e-mail communications: one between her and her press agent, Ross Gow, and another between her and her former boyfriend, convicted pedophile Jeffrey…
gov.uscourts.nysd.447706.440.1.pdf PDF
…Churcher to Subpoena also commands to bring with her to the documents: deposition several broad categories of documents: 1. 1. Documents containing communications with All Documents Roberts. Virginia …
gov.uscourts.nysd.447706.1330.21.pdf PDF
…are hereby notified that any dissemination, distribution or copying of the information contained herein is strictly unauthorize d and prohibited. If you have received this communication in error, please notify the sender immediately and delete this messa ge. Thank you. …
gov.uscourts.nysd.447706.1331.25.pdf PDF
…Exhibit 9 appears 09:21:47 20· ·to have five sentences in it.· Do you agree that those 09:22:03 21· ·same five sentences are part of the communication that is 09:22:10 22· ·borne in Exhibit 2…
gov.uscourts.nysd.447706.218.0.pdf PDF
…compliance, commands Churcher to sit for a deposition and produce a broad array of documents, including “[a]ll documents containing communications” with the Plaintiff and “[a]ll communications with any agent” for the Plaintiff. See Declaration of Laura R. Handman…
gov.uscourts.nysd.447706.15.0.pdf PDF
…false aspersion. It may be said that this is one of the duties that he owes to himself and to his family. Therefore communications made in fair self-defense are privileged. If I am attacked in a newspaper, I may…
gov.uscourts.nysd.447706.1050.0.pdf PDF
…frankly, not every 22 recipient of these notices is the kind of person that has a 23 lawyer on speed dial. 24 We also think that it can be hard to -- communications 25 are more difficult now. So we certainly…
gov.uscourts.nysd.447706.1090.46.pdf PDF
…Plaintiff’s statements to the press were lies, and now even Plaintiff is saying that the press “got it wrong”. Plaintiff’s counsel similarly would not allow Plaintiff to answer questions regarding her communications with law enforcement, specifically regarding Ms…
gov.uscourts.nysd.447706.230.0.pdf PDF
…counsel did not know these email accounts exist is belied by the fact that they have now included “privileged” communications from at least one of the accounts on their privilege log demonstrating and indicating there are probably privileged communications in…
gov.uscourts.nysd.447706.509.0.pdf PDF
…Hart, 945 F.Supp.2d 494, 503–04 (S.D.N.Y. 2013); MASTR Adjustable Rate Mortgages Trust, 295 F.R.D. at 84; Orbit One Communications, Inc. v. Numerex Corp., 271 F. R.D.2d 429, 438 (S.D…
gov.uscourts.nysd.447706.1325.15.pdf PDF
…Plaintiff’s statements to the press were lies, and now even Plaintiff is saying that the press “got it wrong”. Plaintiff’s counsel similarly would not allow Plaintiff to answer questions regarding her communications with law enforcement, specifically regarding Ms…
gov.uscourts.nysd.447706.49.0.pdf PDF
…1(A), Plaintiff attaches correspondence between counsel while misrepresenting the facts relating to those communications. The Law Under Rule 26(c) of the Federal Rules of Civil Procedure any party may move the court, for good cause shown, for a…
gov.uscourts.nysd.447706.551.0.pdf PDF
…11th Cir. 1983) .................................................................................................... 5 Newsday LLC v. Cty. of Nassau, 730 F.3d 156 (2d Cir. 2013)........................................................................................................ 7 Nixon v. Warner Communications, 435 U.S. 589 (…
gov.uscourts.nysd.447706.436.0.pdf PDF
…concerns .3 Although Ms. Giuffre dismisses the Requested Documents as irrelevant, they indisputably 3 The fact that the Emails involve communications with a reporter neither implicates any privilege nor justifies confidentiality protections. The Emails are in Ms. Giuffre’s possession…
gov.uscourts.nysd.447706.555.0.pdf PDF
…Hart, 945 I F.Supp.2d 494, 503- 04 (S.D.N.Y. 2013); MASTR Adjustable Rate Mortgages Trust, 295 F.R.D. I at 84; Orbit One Communications, Inc. v. Numerex Corp., 271 F. R.D.2d 429, 438…