…individual, firm, partnership, association, joint venture, estate, trust, receiver, syndicate, enterprise or combination, corporation or other legal, business or government entity. 12. “Relate,” “relating,” “relates” means concerning, referring to, responding to, relating to, pertaining to, connected with, evidencing, commenting on…
…attaches to all judicial documents. Maxwell’s repeated assertion that these documents are entitled to “a minimal presumption of access” is directly contradicted by the Second Circuit’s conclusion that “the presumption of access to “materials submitted in connection with…
…a past or present officer, director, agent or servant, including any attorney (associate or partner) or paralegal. 7. “Including” means including without limitations. 8. “Jeffrey Epstein” includes Jeffrey Epstein and any entities owned or controlled by Jeffrey Epstein, any employee…
…a past or present officer, director, agent or servant, including any attorney (associate or partner) or paralegal. 5. "Including" means including without limitations. 6. "Jeffrey Epstein" includes Jeffrey Epstein and any entities owned or controlled by Jeffrey Epstein, any employee…
…a past or present officer, director, agent or servant, including any attorney (associate or palinel') or paralegal. 7. "Including" means including without limitation. g. "Jeffrey Epstein" includes Jeffrey Epstein and any entities owned or coniTolled by Jeffrey Epstein, any employee…
…a past or present officer, director, agent or servant, including any attorney (associate or partner) or paralegal. 6. “Including” means including without limitations. 7. “Jeffrey Epstein” includes Jeffrey Epstein and any entities owned or controlled by Jeffrey Epstein, any employee…
…a past or present officer, director, agent or servant, including any attorney (associate or partner) or paralegal. 5. "Including" means including without limitations. 6. "Jeffrey Epstein" includes Jeffrey Epstein and any entities owned or controlled by Jeffrey Epstein, any employee…
…a past or present officer, director, agent or servant, including any attorney (associate or partner) or paralegal. 7. “Including” means including without limitations. 8. “Jeffrey Epstein” includes Jeffrey Epstein and any entities owned or controlled by Jeffrey Epstein, any employee…
…of the Reliance Finally, courts examine the ways in which those from whom discovery is sought – both parties and non-parties – conducted themselves in reliance on a protective order. For example, courts consider whether discovery was provided that otherwise could…
…and get through Internet. 18 Q. Okay. So, is it your understanding that 19 the only connection then through Citrix with these 20 computers, these various computers that were in 21 Mr. Epstein's home, w…
…and get through Internet. 18 Q. Okay. So, is it your understanding that 19 the only connection then through Citrix with these 20 computers, these various computers that were in 21 Mr. Epstein's home, w…
…gathered in course C of investigations into incident – Dominant purpose of investigations so that solicitors could provide legal advice in connection with expected proceedings – Implied statutory duty to investigate but no duty to report – Affidavits did not enable court to…
…21 MR. PAGLIUCA: This is not a document that has been 22 produced by the plaintiffs, and it has never been labeled as 23 confidential in connection with this case. 24 MS. McCAWLEY: Sorry. I was concerned about that. 25…
…2015) (Sweet, J.). Since the Defendant still refuses to provide transparency into her document collection efforts as of filing this Reply brief, a forensic examination of Defendant’s electronic data, conducted by a neutral expert, is appropriate to ensure that…
…Maxwell, Case No. J5-cv-07433-RWS Dear Honorable Judge Sweet: 1 represent defendant Ghislaine Maxwell in connection with the above-referenced action. I write pursuant to Section 1.E. of Your Honor's Individual Practice Rules to request an…
…23, 2020, hearing, the Court held that Defendant “fail[ed] to rebut the presumption of public access to the motions at issue and the documents filed in connection with those motions. Accordingly, those papers shall be unsealed.” July 23, 2020…
…10007 RE: Giuffre v. Maxwell, Case No. 1:15-cv-07433-LAP Dear Judge Preska: Doe 171 writes in connection with her December 5, 2022 letter motion, (Doc. 1285), to supplement the docket entry numbers she believes should remain under…
…Maxwell; 15-CR-07433 (LAP) Dear Judge Preska: My firm represents non-party “J Doe 12” in connection with proceedings concerning the continued sealing/unsealing of various documents in the above-captioned case. I write in connection with the government…
…the district court is better suited to the task. As the Court’s opinion recognizes in connection with the remaining sealed materials, the district court is better positioned to communicate with the parties and any nonparties whose privacy interests might…
…the district court is better suited to the task. As the Court’s opinion recognizes in connection with the remaining sealed materials, the district court is better positioned to communicate with the parties and any nonparties whose privacy interests might…
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