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.447706.288.1.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.447706.1330.17.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.447706.1328.2.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.447706.562.2.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…
gov.uscourts.nysd.447706.1090.7.pdf PDF
…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…
gov.uscourts.nysd.447706.1325.15.pdf PDF
…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…
gov.uscourts.nysd.447706.1206.4.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.447706.132.1.pdf PDF
… 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…
gov.uscourts.nysd.447706.996.0.pdf PDF
…Maxwell’s Brief). This argument shows Mr. Dershowitz is not above mischaracterizing his opponent’s position to set up a straw man argument for himself. We said, “Materials submitted to the court solely so that the court may decide whether…
gov.uscourts.nysd.447706.1069.0.pdf PDF
…to that, your Honor, I'm really 17 commenting on the issue of what someone could reasonably have 18 relied upon, and the issue that someone would have thought of 19 at that point in time was public disclosure, and…
gov.uscourts.nysd.447706.1218.14.pdf PDF
…of the same color of his own words " Pussy", and covered my face from the unexpected intrusion. Jeffrey got up and wrapped a towel around his loins and answered the door completely calm. Opening the bedroom door and letting Alan …
gov.uscourts.nysd.447706.1201.10_1.pdf PDF
…fact, seeking only to response Plaintiff on one subject: “Defendant should be ordered to sit for a follow-up deposition and directed to answer questions regarding her knowledge of alleged “adult” sexual activity.” Plaintiff’s Motion to Compel Deposition Questions…
gov.uscourts.nysd.447706.1166.0_1.pdf PDF
…594 F.2d 291 (2d Cir. 1979). She claims it is irrelevant because it concerned the government’s – rather than the public’s – right to access documents covered by a protective order. In fact, this unsealing came about after a…
gov.uscourts.nysd.447706.1224.0.pdf PDF
…an approach, however, would delay speeding up the process until after her criminal proceedings,3 and will only to lead to more disputes. Even deciding what groups should exist and what to call them will likely lead to disagreement, and…
gov.uscourts.nysd.447706.1327.26.pdf PDF
…fact, seeking only to response Plaintiff on one subject: “Defendant should be ordered to sit for a follow-up deposition and directed to answer questions regarding her knowledge of alleged “adult” sexual activity.” Plaintiff’s Motion to Compel Deposition Questions…
gov.uscourts.nysd.447706.949.0.pdf PDF
…one of them had 11 to do with plaintiff and plaintiff's passport information, and 12 plaintiff has agreed to open the whole file up. 13 Now, maybe they'll have some things they'll want to 14 redact -- we…
gov.uscourts.nysd.447706.1335.2.pdf PDF
…this case. If you instruct her not to 19 answer, all you're going to do is bring 20 her back. That's up to you. 21 MR. PAGLIUCA: It's up…
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