…is that the public interest might otherwise be harmed if extremely sensitive material were to lose this special shield of confidentiality.2 Whether the privilege applies is determined by balancing the needs of the plaintiffs against the needs of the…
…designations. May 4, 2107, Pre-trial Conference to address any outstanding issues including confidentiality. WHEREFORE, the parties request that the Court adopt the proposed schedule and modify the Court' s Order of October 3, 2016 to reflect the above deadlines…
…and correct copies of conferral communication between counsel, including a true and correct copy of Jeffrey Epstein’s written waiver of claims concerning settlement agreement’s confidentiality provision dated August 16, 2016. 4. Attached as Exhibit C (filed under seal…
…because Ms. Giuffre corrected some typographical and spelling issues. 2 confidentiality designations of that type of discovery would wrongfully allow the abuser to hide behind a claim of confidentiality. Purposes and Limitations: Ms. Giuffre’s proposed revisions include…
…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 …
…case. In unsealing the summary judgment record, the Court of Appeals redacted “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 v. Maxwell…
…Giuffre requests that this Court maintain the confidentiality designations over these police reports and direct the Defendant to disclose all the recipients of the 1 Case 1:15-cv-07433-LAP Document 1199-1 Filed 01/27/21 Page…
…Id. at 2. As this Court knows, the Second Circuit spoke directly to the issues of confidentiality and unsealing of documents in this case and specifically vacated two of the three decisions cited by Maxwell. Brown v. Maxwell, 929 F…
…from when she was a child, some of them concerning her being raped when only 14 years. Defendant’s challenge to Ms. Giuffre’s confidentiality designation is without merit, and it is for improper purposes. Therefore, it should be denied…
…2017, this Court ordered: “[A]ll documents, materials, and information subject to the Protective Order must be returned to the party who designated its confidentiality as of the date this action was dismissed.” Id. 2 (emphasis supplied). Ms. Giuffre and…
…that a non-party cannot seek to overturn the protective order as follows: “The Protective Order states that parties can object to the confidentiality designations: “A party may object to the designation of particular CONFIDENTIAL INFORMATION by giving written notice…
…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…
…sealed in Maxwell.” DE 233, at 2. The Court’s revised language underscored that “the parties may only agree to remove confidentiality designations for Ms. Giuffre’s personal documents” from Maxwell, “i.e., those bearing her bates stamp in Maxwell…
…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…
…by its redactions, implicitly held that the deposition contained “responses concerning intimate matters where the questions were likely only permitted – and the responses only compelled – because of a strong expectation of continued confidentiality.” See Resp. at 5 (“this court should…
…for the sake of efficiency, re-produced in the Dershowitz case her document productions from the Maxwell case with whatever confidentiality designations were originally applied in the Maxwell case. Recognizing that some documents which Ms. Giuffre designated as confidential in…
…but a confidentiality order shall be entered. Regarding the deposition: The depo shall be limited to 4 hours without prejudice to request additional time in the future. The Defendant can be present at the depo. The depo will be taken…
…No. 12 All confidentiality agreements between you and Jeffrey Epstein or any entity to which he is related or involved or such agreements which are or were in your possession or control related to any other employee of Jeffrey Epstein…
…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…
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