gov.uscourts.nysd.447706.1090.36_1.pdf PDF
…am so close to wrapping up an era, just need a couple dates confirmed is all. If you aren't sure about the dates which you have already said that's fine. I have turned the Wilton Manors police dept…
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gov.uscourts.nysd.447706.1326.4.pdf PDF
…am so close to wrapping up an era, just need a couple dates confirmed is all. If you aren't sure about the dates which you have already said that's fine. I have turned the Wilton Manors police dept…
gov.uscourts.nysd.447706.1320.39.pdf PDF
…am so close to wrapping up an era, just need a couple dates confirmed is all. If you aren't sure about the dates which you have already said that's fine. I have turned the Wilton Manors police dept…
1320-39.pdf PDF
…am so close to wrapping up an era, just need a couple dates confirmed is all. If you aren't sure about the dates which you have already said that's fine. I have turned the Wilton Manors police dept…
gov.uscourts.nysd.447706.1320.10.pdf PDF
…articulated below.2 2 Ms. Giuffre’s counsel met and conferred with Defendant’s counsel both in person and by phone in an effort to obtain agreement to proceed with these depositions but was unable to obtain an agreement. See …
gov.uscourts.nysd.447706.1295.11.pdf PDF
…Party Witness to Produce Documents and Respond to Deposition Questions, and Response to Motion for Protective Order for Non-Party Witness (ECF 640)1 and further states as follows: STATEMENT OF CONFERRAL The undersigned has conferred with Mr. Stanley Pottinger…
gov.uscourts.nysd.447706.1330.3.pdf PDF
…In such a case 'even where the plaintiff can show no actual damages at all, a plaintiff who has otherwise shown defamation may recover at least nominal damages' and the Second Circuit also confirmed an award of punitive damages). Ms…
gov.uscourts.nysd.447706.1328.23.pdf PDF
…AMD, 2010 WL 2483294, at *3 (D.N.J. June 4, 2010). That pre-trial discovery on financial matters is allowed when a punitive damage issue is present in a case is confirmed by Tillery v. Lynn, 607 F. Supp…
1320-10.pdf PDF
…articulated below.2 2 Ms. Giuffre’s counsel met and conferred with Defendant’s counsel both in person and by phone in an effort to obtain agreement to proceed with these depositions but was unable to obtain an agreement. See …
gov.uscourts.nysd.447706.1331.30.pdf PDF
…Party Witness to Produce Documents and Respond to Deposition Questions, and Response to Motion for Protective Order for Non-Party Witness (ECF 640)1 and further states as follows: STATEMENT OF CONFERRAL The undersigned has conferred with Mr. Stanley Pottinger…
gov.uscourts.nysd.447706.155.0.pdf PDF
…of Civil Procedure 37(a)(1), undersigned counsel certifies that she conferred with opposing counsel regarding the issues contained herein and attempted to reach resolution on these issues without need for Court intervention. The parties have been unable to reach…
gov.uscourts.nysd.447706.1307.4.pdf PDF
…articulated below.2 2 Ms. Giuffre’s counsel met and conferred with Defendant’s counsel both in person and by phone in an effort to obtain agreement to proceed with these depositions but was unable to obtain an agreement. See …
gov.uscourts.nysd.447706.562.2.pdf PDF
…Cole, 950 So. 2d 380 (Fla. 2007). Defamatory statements made by lawyer while interviewing a witness in preparation for and connected to pending litigation are covered by the absolute immunity conferred by the litigation privilege. See DelMonico v. Traynor, 50…
gov.uscourts.nysd.447706.46.0.pdf PDF
…Mr. Epstein and their counsel were not in a common interest agreement without once having conferred regarding that fact and with knowledge that all of the elements of a common interest agreement are satisfied in this case. 1 Ms. Maxwell…
gov.uscourts.nysd.447706.1137.12_2.pdf PDF
…articulated below.2 2 Ms. Giuffre’s counsel met and conferred with Defendant’s counsel both in person and by phone in an effort to obtain agreement to proceed with these depositions but was unable to obtain an agreement. See …
gov.uscourts.nysd.447706.1256.3.pdf PDF
…articulated below.2 2 Ms. Giuffre’s counsel met and conferred with Defendant’s counsel both in person and by phone in an effort to obtain agreement to proceed with these depositions but was unable to obtain an agreement. See …
gov.uscourts.nysd.447706.1295.14.pdf PDF
…Palm Beach Police Officer Michele Pagan got a disturbing message. A woman reported that her 14-year-old stepdaughter confided to a friend that she'd had sex with an older man for money. The man's name was Jeff…
gov.uscourts.nysd.447706.1330.15.pdf PDF
…District Court for the Southern District of New York. Counsel for Ms. Giuffre has conferred with counsel for Epstein, and counsel for Epstein has agreed to the filing of the Motion to Compel under seal. III. CONCLUSION For the reasons…
gov.uscourts.nysd.447706.59.0.pdf PDF
…1:15-cv-07433-LAP Document 59 Filed 03/15/16 Page 5 of 5 CERTIFICATE OF GOOD FAITH The undersigned hereby certifies that Counsel for Plaintiff conferred with Defendant’s Counsel by sending a detailed letter detailing the request…