gov.uscourts.nysd.447706.1302.0.pdf PDF
MANDATE CaseCase 22-1836, Document 1:15-cv-07433-LAP 57, 07/19/2023, Document 3543747, 1302 Filed Page1 07/19/23 of 31 of 3 …
MANDATE CaseCase 22-1836, Document 1:15-cv-07433-LAP 57, 07/19/2023, Document 3543747, 1302 Filed Page1 07/19/23 of 31 of 3 …
…in-line, in black, below to your email sent yesterday. My in-line communication should also be responsive to the email that you just sent. If I have left anything out, please let me know. Thanks, Meredith Meredith L. Schultz…
…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…
… CLARIFICATION OF THIS COURT’S MARCH 17, 2016 RULING.................................3 A. Documents Evidencing Communications and Interactions With Co-Conspirators.............................................................................................................3 B. Documents Concer…
…2 1. Ms. Giuffre’s Counsel’s Communications With the Media Are Outside the Scope of Rule 26 and Any Attempt at Collection Would be Unduly Burdensome ..............................................................................2 …
…upon the pleadings and papers in this matter, and the accompanying Memorandum of Law, Movant-Intervenor TGP Communications, LLC, d/b/a The Gateway Pundit (“Intervenor”) respectfully moves and seeks leave to intervene in the above- captioned matter pursuant to…
…Despite these obstacles, non-party Ransome complied by producing over 235 pages of highly relevant documents which include photographic evidence and e-mail communications during the mid-2000s that directly contradict Defendant’s deposition testimony. For example, Defendant swore under…
…Maxwell, 15 Civ. 7433 (LAP) Dear Judge Preska: We write on behalf of non-party John Doe in response to Movant-Intervenor TGP Communications, LLC, d/b/a The Gateway Pundit’s (“TGP’s”) motion to intervene and unseal materials…
… : : Defendant. : : ----------------------------------------------------------x MEMORANDUM OF LAW IN SUPPORT OF PROPOSED INTERVENOR TGP …
…… 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…
…P. Specifically, Ms. Giuffre objects to the requests as overly burdensome to the extent that they would require logging voluminous and ever-increasing privileged communications between Ms. Giuffre and her counsel after the date litigation commenced on September 21, 2015…
…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…
…this Court should grant Ms. Giuffre’s requests Nos .1-3. Defendant states that the material responsive to Ms. Giuffre’s requests Nos. 2-3 constitute “privileged communications between (a) Ms. Maxwell’s attorneys and Ms. Maxwell, (b) defense counsel…
…RFP Nos. 6-7, 9-10: Joint defense agreements and related documents. .................... 9 D. RFP No. 11: Communications between defense counsel and Mr. Dershowitz’s attorneys. .................................................................................................................. 11 E. RFP No. 12: Doc…
…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…
…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 this Response in accordance with…
…P. Specifically, Ms. Giuffre objects to the requests as overly burdensome to the extent that they would require logging voluminous and ever-increasing privileged communications between Ms. Giuffre and her counsel after the date litigation commenced on September 21, 2015…
…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 this Response in accordance with…
…and Judy E. Zelin, J.D. V. Privileged Communications and Confidential Matters D. Particular Privileges and Confidential Matters Under Common Law Summary Correlation Table References §…
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