…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…
…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…
…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 All manuscripts and/or other writings, whether published or unpublished, created in whole or in part by you, concerning, relating or referring to Jeffrey Epstein and any of his agents or associates. 24.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…
…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…
…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…
…considered to be within the relevant time frame if it refers or relates to communications, meetings or other events or documents that occurred or were created within that time frame, regardless of the date of creation of the responsive Document. …
…Defendant’s documents concerning Ms. Giuffre are directly relevant to this action, particularly because Defendant has created multiple drafts of statements to the press defaming Ms. Giuffre. Throughout the months of motion practice concerning these issues, and throughout all of…
…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…
…Defendant’s documents concerning Ms. Giuffre are directly relevant to this action, particularly because Defendant has created multiple drafts of statements to the press defaming Ms. Giuffre. Throughout the months of motion practice concerning these issues, and throughout all of…
…Defendant’s documents concerning Ms. Giuffre are directly relevant to this action, particularly because Defendant has created multiple drafts of statements to the press defaming Ms. Giuffre. Throughout the months of motion practice concerning these issues, and throughout all of…
…attorney competencies belies this statement.2 First, it is expected that the overwhelming majority of documents “concerning” Ms. Giuffre are attorney-client communications or work product created after the filing of this lawsuit. Such documents do not even require extensive…
…considered to be within the relevant time frame if it refers or relates to communications, meetings or other events or documents that occurred or were created within that time frame, regardless of the date of creation of the responsive Document. …
…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…
…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…
…considered to be within the relevant time frame if it refers or relates to communications, meetings or other events or documents that occurred or were created within that time frame, regardless of the date of creation of the responsive Document. …
…Q. Okay. My question was bad. 18 I know that the first person interviewed 19 that kind of kicked off the investigation was SG, 20 but -- and just to create a picture of what we have 21 here, this is…
…because a “party’s failure to produce evidence within its control creates a presumption that evidence would be unfavorable to that party” an adverse inference should be applied with respect to Defendant’s failure to produce data from the email…
…because a “party’s failure to produce evidence within its control creates a presumption that evidence would be unfavorable to that party” an adverse inference should be applied with respect to Defendant’s failure to produce “in order to ensure…