…interrogatories, responses to requests for admission, deposition testimony, and other information disclosed pursuant to the disclosure or discovery duties created by the Federal Rules of Civil Procedure. 2. As used in this Protective Order, “document” is defined as provided in…
….............. 60 5. The January 2015 statement accurately denied that Ms. Maxwell created and distributed child pornography and that the Government knows of and possesses such child pornography. ..............................................…
…2006) (“Documents created by or at the behest of counsel and presented to a court in order to sway a judicial decision are judicial documents.”). Undecided motions and their accompanying papers fit the definition of judicial documents as articulated in…
…no. 978]), which the Protocol was created to help facilitate. Accordingly, Protocol Section 3(f) states that “[t]he Court will conduct a particularized review of the Sealed Materials and weigh the competing interests regardless whether it receives any Non…
…interrogatories, responses to requests for admission, deposition testimony, and other information disclosed pursuant to the disclosure or discovery duties created by the Federal Rules of Civil Procedure. 2. As used in this Protective Order, “document” is defined as provided in…
…Now, after having created a last- minute scramble to conduct discovery on facts far removed in time and circumstance from Plaintiff’s defamation claim, Plaintiff now complains that too much is being asked of her “witness.” Plaintiff protests that the…
…Maxwell’s sexual activities. Ultimately the Court created the boundaries of discoverable matters and at the parties’ request entered a protective order that allowed the parties to provide discovery on highly private and sensitive subjects that could not be disclosed…
…Now, after having created a last- minute scramble to conduct discovery on facts far removed in time and circumstance from Plaintiff’s defamation claim, Plaintiff now complains that too much is being asked of her “witness.” Plaintiff protests that the…
…as aphysician. ”). A ccord ingly,“certainty”thatevery med icalrecord ever created forM s.Giu ffre,across nearlytwo d ecad es and two continents is achimera-end less time and resou rces cou ld neverprod u ce su ch certainty. 2…
…his agents or associates. 23. All manuscripts and/or other writings, whether published or unpublished, created in whole or in part by you, concerning, relating or referring to Jeffrey Epstein and any of his agents or associates. 24. All documents…
…the issues; documents that are not relevant to any party’s claim or defense; and documents that are not proportional to the needs of the case. Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such…
…and were used for those who claimed they were victims to receive financial payment to be shared between them and their lawyers. One firm created and sold fake cases against Mr. Epstein – the firm subsequently imploded and the (sic) Rothstein…
…rendition of legal services to the client). Some Florida courts have even recognized serious due process issues could be created by a procedure through which a client lost their privilege without an opportunity to be heard in the proceedings. See…
…relevant documents. (DE 345 at pg. 8). However, it appears that Jeffrey Epstein created the mindspring.org accounts to communicate with his household and with his employees, and did, in fact, communicate with them this way. As previously recounted, Jeffrey…
…from them. 2 Case 1:15-cv-07433-LAP Document 1090-18 Filed 07/30/20 Page 4 of 11 Plaintiff makes a bizarre argument that somehow this testimony can be used to create an adverse inference against Ms…
…relationship was with Barden; (3) or who drafted the original communication at the bottom of the email, as it does not appear to have been created by either Defendant or Epstein. As Plaintiff is fully aware, Ms. Maxwell already fully…
…of these communications between Plaintiff and Churcher, it is obvious that stories in the book – later to become allegation in the Joinder Motion – were created and supported based on the suggestions of Churcher. They were not reported by Plaintiff in…
…of supporting evidence.2 Instead, according to Dershowitz, these materials create some sort of a web of circumstantial inferences suggesting his innocence. His attenuated reasoning hardly provides the kind of compelling reason needed to pierce the Protective Order. Instead, Dershowitz…
…that the court file, which includes only some of the documents created during discovery, totals in the “thousands of pages”). Giuffre sought and obtained a wide variety of private and confidential information about Maxwell and others, including information about financial…
…there is no indication or inference that either of these accounts were created or used in the 2000 to 2002 time frame as Plaintiff claims. 3 Case 1:15-cv-07433-LAP Document 1330-16 Filed 01/05/24…
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