…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…
…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 …
…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…
…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…
…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 …
…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 …
…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…
…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: …
… 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…
…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…
…sticking out 10 in your brain as being topless? 11 A. Yes. 12 Q. And the walls on the staircase to the 13 upstairs were not just covered with nude 14 photographs, to your recollection? 15 A. To my recollection…
…Scarola, at which 22 time I will give opportunity for re-direct based 23 upon the topics that you've raised. 24 MR. SCAROLA: With the understanding that 25 re-direct is going to be limited to the area of…
…36 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 But having…
… Case 1:15-cv-07433-LAP Document 1137-14 Filed 10/22/20 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…
…deposition. 1 Case 1:15-cv-07433-LAP Document 1325-15 Filed 01/04/24 Page 4 of 14 covered and which were necessitated by Plaintiff’s late disclosures and refusal to answer questions at her first deposition. ARGUMENT…
… 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…
…s, 14 and was dismissed shortly thereafter. Two times since May we 15 have asked for agreed upon protocol with the plaintiff's 16 counsel to finish up destroying or exchanging-back confidential 17 documents. The first request was shortly…
…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 …
…be heard is both Constitutionally required and appropriate under the circumstances. This case is of obvious, significant public interest, and the events underlying the lawsuit have been covered extensively in the press, including in the Post and Daily News. However…
… This 21 case is about the plaintiff's false allegations. 22 THE COURT: Yes. I think I picked up on that. 23 MR. PAGLIUCA: These are the lawyers that wrote the 24 false allegations. 25 THE COURT: I think I…