…… and government agents and police officers, not to release or authorize the release of non- public information or opinion which a reasonable person would expect to be disseminated by means of public communication, in connection with pending or imminent…
…on information currently known to her and are given without waiving Ms. Maxwell’s right to use evidence of any subsequently discovered or identified facts, documents or communications. Ms. Maxwell reserves the right to supplement these Interrogatories in accordance with…
…is codified under Florida's Title VII Evidence. The statute provides that neither an attorney nor a client may be compelled to divulge confidential communications between a lawyer and client which were made during the rendition of legal services. Fla…
…representations, and the nature of their representations. Interrog. 3. Plaintiff and her attorneys’ communications with law enforcement, including the dates of the communications and the parties to the communication. Interrog. 4. Plaintiff’s employment from 1996 – present, including…
…During that call, Epstein himself got on the phone (a means of interstate communication) with Jane Doe #4, asking her personally to come to his mansion in Palm Beach. Jane Doe #4 then went to Epstein’s mansion and was…
…li 2 Q. Okay . Ever since this communication that 2 t ime I went to the deposition I was in Palm 3 Ms. Maxwell made to you where she called you 3 Beach and I did my duty, I mean…
… Even under Rule 26, it is a hopelessly 2 broad subpoena. It is abusive civil discovery and on the face 3 of it appears to violate the Electronic Communications Privacy 4 Act and the Stored Communications Act, federal laws. The…
…not one 4 bit, and I think they have waived the privilege on it by not 5 producing a privilege log. 6 With respect to our request for her communications 7 with witnesses in this case, those were requests one…
…During that call, Epstein himself got on the phone (a means of interstate communication) with Jane Doe #4, asking her personally to come to his mansion in Palm Beach. Jane Doe #4 then went to Epstein’s mansion and was…
…the core, sworn statement from Sharon Churcher that, “at all times,” when she was in communication with Plaintiff Virginia Giuffre (referred to as “Virginia Roberts”) or her agents, Churcher “was acting in [her] capacity as a journalist with Ms. Roberts…
…Sent: Tuesday, 8 March 2011 4:06 AM To: Virginia Giuffre Cc: Bardfeld, Wende E. (FBI) Subject: FW: Confidential contact information .Dear Virginia: Please treat this as a confidential communication. at 9:00 a.m. your time, Tuesday, Mar Thank…
…the first 2 Q. Okay. Ever since this communication that 2 time I went to the deposition I was in Palm 3 Ms. Maxwell made to you where she called you 3 Beach and I did my duty, I mean…
…During that call, Epstein himself got on the phone (a means of interstate communication) with Jane Doe #4, asking her personally to come to his mansion in Palm Beach. Jane Doe #4 then went to Epstein’s mansion and was…
…li 2 Q. Okay . Ever since this communication that 2 t ime I went to the deposition I was in Palm 3 Ms. Maxwell made to you where she called you 3 Beach and I did my duty, I mean…
…the core, sworn statement from Sharon Churcher that, “at all times,” when she was in communication with Plaintiff Virginia Giuffre (referred to as “Virginia Roberts”) or her agents, Churcher “was acting in [her] capacity as a journalist with Ms. Roberts…
…need 13 to be left alone. 14 Q. Okay. I understand. 15 Have you had any communication with anyone 16 who represents the interests of Ghislaine Maxwell in 17 the last -- 18 A. Absolutely not. 19 Q. Okay. 20 A…
…be summarised as follows. (1) All communications between a client or his legal adviser and third parties are prima facie privileged if one of the purposes for which they are made is the purpose of pending or contemplated litigation. (2)…
…During that call, Epstein himself got on the phone (a means of interstate communication) with Jane Doe #4, asking her personally to come to his mansion in Palm Beach. Jane Doe #4 then went to Epstein’s mansion and was…
…one of the largest and 17 most significant pieces to us are the assertions by plaintiff 18 that her own communications with law enforcement are somehow 19 protected by -- 20 THE COURT: I'm prepared to deal with that. 21…
…279: Motion for Adverse Inference Instruction, Dkt. 143: Motion to Compel Defendant to Answer Deposition Questions, and Dkt. 164: Motion to Compel all Attorney-Client Communications and Work Product. Sincerely, /s/ Sigrid S. McCawley …
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