…and Law Enforcement are not news- gathering activities ........................................................................................................... 7 II. THE ABSOLUTE PRIVILEGE OF THE SHIELD LAW IS NOT APPLICABLE BECAUSE THERE WAS NO EXPECTATION OF CONFIDENTIALITY ..................... 9 …
…Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 • Main 303.831.7364 FX 303.832.2628 [email protected] www.hmflaw.com CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail…
…Intervenor’s June 21, 2017 letter and its attachments, and remove the confidentiality designation from several related emails and attachments that the parties previously designated confidential (RANSOME_000273-557) (“the Emails”). The Emails will demonstrate that Ms. Ransome’s inflammatory…
…that this is fishing with a drift net. We decline your request to engage in this exercise. Regarding redacted police reports that plaintiff designated “confidential”: We objected to plaintiff’s confidentiality designation, and plaintiff failed to file a motion in…
…Sweet: This firm represents Intervenor Professor Alan M. Dershowitz, and we write in anticipation of the parties’ forthcoming motion practice concerning the confidentiality of the Sarah Ransome deposition. 1 Intervenor requests that, if the Court allows Plaintiff Virginia Giuffre to…
…Sweet: This firm represents Intervenor Professor Alan M. Dershowitz, and we write in anticipation of the parties’ forthcoming motion practice concerning the confidentiality of the Sarah Ransome deposition. 1 Intervenor requests that, if the Court allows Plaintiff Virginia Giuffre to…
…stipulates to the motion to the extent that it asks for a Court order directing her to produce the agreement, subject to the confidentiality order previously entered in this case. Ms. Giuffre asks for the Court to endorse this letter…
…fairly obvious that this is fishing with a drift net. We decline your request to engage in this exercise. Regarding redacted police reports that plaintiff designated “confidential”: We objected to plaintiff’s confidentiality designation, and plaintiff failed to file a …
…Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 • Main 303.831.7364 FX 303.832.2628 [email protected] - www.hmflaw.com - CONFIDENTIALITY NOTICE: This e-mail tran…
…2016. Case 1:15-cv-07433-LAP Document 76 Filed 03/31/16 Page 2 of 2 4. Attached as Exhibit C is a true and correct copy of the Confidentiality Order issued in Edwards and Cassell v. Dershowitz…
…and redacting all substantive references to them, pending disposition of this application. Although I have erred on the side of strict confidentiality to avoid any semblance of violating the Court’s Protective Order, I of course do not believe that…
…SUBPOENA SEEKS DOCUMENTS THAT ARE PRIVILEGED FROM DISCLOSURE BY THE NEW YORK SHIELD LAW ............................ 6 A. To the Extent the Subpoena Seeks Information Received Pursuant to Promises of Confidentiality, Such Information Is Absolutely …
…from deposition testimony and police reports, as well as deposition responses concerning intimate matters where the questions were likely only permitted—and the responses only compelled—because of a strong expectation of continued confidentiality.” Brown, 929 F.3d at 48…
…per the March 21, 2016 meet and confer phone call, we are addressing with the Plaintiff whether she will reveal here address to Defendant’s counsel confidentially and we will update you with her response. a. Due to safety concerns…
…10 MR. CRITTON: Form . 11 friends with Jeffrey Epstein or is it that you 11 THE WITNESS: She knew what was going on. 12 have information and you have this confidentiality 12 BY MR. EDWARDS: 13 but you're revealing…
…Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 • Main 303.831.7364 FX 303.832.2628 [email protected] www.hmflaw.com CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail…
…per the March 21, 2016 meet and confer phone call, we are addressing with the Plaintiff whether she will reveal here address to Defendant’s counsel confidentially and we will update you with her response. a. Due to safety concerns…
…per the March 21, 2016 meet and confer phone call, we are addressing with the Plaintiff whether she will reveal here address to Defendant’s counsel confidentially and we will update you with her response. a. Due to safety concerns…
…Florida, including any application for Employment. 9 Case 1:15-cv-07433-RWS Document 71-6 Filed 03/23/16 Page 14 of 19 11. Any Document reflecting any confidentiality agreement by and between, or concerning, You and the…
…Ms. Giuffre is entitled to seek and retrieve that electronic data. 2 Case 1:15-cv-07433-LAP Document 121 Filed 04/25/16 Page 4 of 10 by a neutral court-appointed expert” under a confidentiality agreement). Such…
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