…and in the face of Plaintiff’s sworn denial that she has had any contact with law enforcement officials from 1996 to the present apart from supposed “active investigations involving Ghislaine Maxwell,” counsel for Defendant unearthed numerous records of such…
…Doe #1, Doe #2, and Doe #3. Provide the address or contact information for each Non-Party or his or her legal counsel, which the Original Parties identified to the best of their ability. 2. Judicial Adjudication: Because of…
…Doe #1, Doe #2, and Doe #3. Provide the address or contact information for each Non-Party or his or her legal counsel, which the Original Parties identified to the best of their ability. 2. Judicial Adjudication: Because of…
…Doe #1, Doe #2, and Doe #3. Provide the address or contact information for each Non-Party or his or her legal counsel, which the Original Parties identified to the best of their ability. 2. Judicial Adjudication: Because of…
…were necessary. Undersigned counsel also asked defendant's counsel to either advise the Court that it was both sides' position that no redactions were necessary or to contact the undersigned. In the two weeks since that email was sent, defense…
…Doe #1, Doe #2, and Doe #3. • Provide the address or contact information for each Non-Party or his or her legal counsel, which the Original Parties identified to the best of their ability. 2. Judicial Adjudication: Because of the…
…specific position as to each document at issue is also included in the chart attached to this brief as Exhibit A. 2 The Brown minimal redactions encompass: (1) “personally identifying information such as personal phone numbers, contact lists, birth dates…
…sentences or paragraphs it would be redacting. Instead the panel said it was redacting “personal phone numbers, contact lists, birth dates, and social security Case 1:15-cv-07433-LAP Document 1020 Filed 01/17/20 Page 3 of…
…time contended that Doe 1 needed to be provided with a second Non-Party notice because she had “received new contact information for Doe 1.” The Protocol is clear on how the Original Parties are to effect Notice on Non…
…LAP Document 1284 Filed 12/02/22 Page 14 of 17 14 1 another note here. To the extent that there is personal 2 contact information in any of these excerpts, needless to say, 3 that should remain sealed. 4 …
…LAP Document 1283 Filed 12/02/22 Page 14 of 17 14 1 another note here. To the extent that there is personal 2 contact information in any of these excerpts, needless to say, 3 that should remain sealed. 4 …
…Accordingly, Maxwell bears the burden of identifying “with specificity competing and compelling interests in closure” and that “those interests outweigh 1 The Brown minimal redactions encompass: (1) “personally identifying information such as personal phone numbers, contact lists, birth dates, and…
…might have a privacy interest at stake. Plaintiff’s counsel declined to say whether they have new contact information for any of the Does for which no address was known by the parties, nor explain why a further attempt to…
…Doe #1, Doe #2, and Doe #3. • Provide the address or contact information for each Non-Party or his or her legal counsel, which the Original Parties identified to the best of their ability. 2. Judicial Adjudication: Because of the…
…Doe #1, Doe #2, and Doe #3. • Provide the address or contact information for each Non-Party or his or her legal counsel, which the Original Parties identified to the best of their ability. 2. Judicial Adjudication: Because of the…
…3. • The Original Parties should also be required to exercise best efforts to identify and provide the Court any available contact information or addresses for each Non-Party or his or her legal counsel. (3) Initial Judicial Adjudication: The Court…
…order was a significant factor 9 in securing the testimony of these witnesses. Counsel for both 10 parties would get contacted by either the deponent or the 11 lawyer for the deponent. And they would raise concerns about 12 what…
…pleadings accused Ms. Maxwell and others of enslaving her when she was a minor and sexually trafficking her to powerful men around the world. She then contacted various media organizations and repeated these false allegations. Along the way, she sold…
…information concerningwho prepared d ocu ments,the location of any copies of su chd ocu ments,the id entities and contactinformation forpersons who have cu stod y orcontrolof su chd ocu ments,the reasons forinability to prod u ce portions…
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