gov.uscourts.nysd.447706.824.0_2.pdf PDF
…1 THE COURT: First order of business from me, have you 2 all reached any decision as to how we're going to conduct the 3 trial with respect to the matters covered by the protective 4 order? 5 MS…
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gov.uscourts.nysd.447706.41.5.pdf PDF
…Plaintiff, v. 15-cv-07433-RWS Ghislaine Maxwell, Defendant. [PROPOSED] PROTECTIVE ORDER Upon a showing of good cause in support of the entry of a protective order to protect the discovery and dissemination of conf…
gov.uscourts.nysd.447706.1097.0_1.pdf PDF
…DERSHOWITZ, Defendant. VIRGINIA L. GIUFFRE, Plaintiff, No. 15 Civ. 7433 (LAP) -against- ORDER GHISLAINE MAXWELL, Defendant. LORETTA A. PRESKA, Senior United States District Judge: The Co…
gov.uscourts.nysd.447706.66.0_1.pdf PDF
…2 of 35 2 G3hdgium 1 THE COURT: Thank you all very much. I'm sorry for 2 the inconvenience that I have imposed upon you. I'm sorry 3 about the inconvenience that you have imposed upon me. 4 …
gov.uscourts.nysd.447706.57.3.pdf PDF
…teams set up by Total and HOSL. The Total defendants and HOSL resist the applications on the B ground that the investigations fall within the rule in Waugh v British Railways Board [1980] AC 521 and are covered by litigation…
gov.uscourts.nysd.447706.288.1.pdf PDF
…We covered a lot of topics and we both had a number of other things to do. 1 EXHIBIT 1 Case 1:15-cv-07433-LAP Document 288-1 Filed 07/15/16 Page 2 of 4 In any…
gov.uscourts.nysd.447706.1218.9.pdf PDF
…girls. The allegation is utterly false—a fabrication from start to finish—but, because I am a well-known law professor and lawyer, it has been widely covered and repeated in the press, both here and around the world. See …
gov.uscourts.nysd.447706.1296.11.pdf PDF
…2) the need of the party for the documents, 3) the breadth of the document request, 4) the time period covered by it, 5) the particularity with which the documents are described, and 6) the burden imposed. Id. 1 …
gov.uscourts.nysd.447706.1295.17.pdf PDF
…2) the need of the party for the documents, 3) the breadth of the document request, 4) the time period covered by it, 5) the particularity with which the documents are described, and 6) the burden imposed. Id. 1 …
gov.uscourts.nysd.447706.1109.0_1.pdf PDF
…08/31/20 Page 2 of 3 of any comments received.” (Id. at 2.)1 The Court writes to provide that update. Nonparties were permitted to submit comments on the proposed disclosure to Mr. Dershowitz no later than August 25…
gov.uscourts.nysd.447706.232.1.pdf PDF
…request in that it is overly broad and seeks confidential financial information. Ms. Giuffre objects to this interrogatory in that it seeks information covered by confidentiality provisions. Ms. Giuffre objects to this information in that any payment information for the…
gov.uscourts.nysd.447706.961.0.pdf PDF
…957), and states as follows. INTRODUCTION1 Ms. Maxwell has argued that counsel for Ms. Giuffre have been ordered by this Court to immediately destroy certain materials covered by the protective order in this matter. Counsel for Mr. Giuffre stand ready…
gov.uscourts.nysd.447706.931.0.pdf PDF
…all refer to it? 20 MR. MILLER: We refer to it as Jane Doe. 21 THE COURT: Okay. 22 MR. MILLER: Let me back up and give you background. 23 THE COURT: No, no. Thanks very much. 24 MR. MILLER: …
gov.uscourts.nysd.447706.1320.18.pdf PDF
… Case 1:15-cv-07433-LAP Document 1320-18 Filed 01/03/24 Page 3 of 40 IV.COMMUNICATIONS WITH ATTORNEY JACK SCAROLA ARE COVERED BY A JOINT DEFENSE AGREEMENT AND ARE THUS PROTECTED BY ATTORNEY- CLIENT AND WORK…
gov.uscourts.nysd.447706.1325.9.pdf PDF
…first walked in the door, it 3 was just myself, and Ghislaine headed for the 4 staircase and said -- told me to come up to the 5 living room. 6 Q. And what happened at that point, when you 7…
gov.uscourts.nysd.447706.1330.17.pdf PDF
…on the subject matters she claims are raised by these two emails, and Plaintiff did in fact question Ms. Maxwell on the subjects covered by the emails. Moreover, despite having access to other email communications that are similar in nature…
gov.uscourts.nysd.447706.363.11.pdf PDF
…Virginia Giuffre in separate pending matters, and shall continue to advance her legitimate legal interests in those matters. As expressly understood by the parties upon the execution of the Confidential Settlement Agreement and Mutual Release, Ms. Giuffre reaffirms her allegations…
gov.uscourts.nysd.447706.1328.2.pdf PDF
…in 11 the investigative incident report? 12 A. I'm not sure if it was updated or not. 13 MR. PAGLIUCA: I don't know if we want to 14 mark this or not. I can hand you what I…
gov.uscourts.nysd.447706.1320.26.pdf PDF
…first walked in the door, it 3 was just myself, and Ghislaine headed for the 4 staircase and said -- told me to come up to the 5 living room. 6 Q. And what happened at that point, when you 7…
gov.uscourts.nysd.447706.562.2.pdf PDF
…Alan Dershowitz, defamed them by repeatedly claiming in worldwide media broadcasts and other widely-disseminated statements that they had engaged in conspiring with their client to make up sexual abuse allegations against Dershowitz. The pleadings and discovery taken to date…
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