…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…
…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…
…to any party’s claim or defense; and documents that are not proportional to the needs of the case. Such requests would create a heavy burden on Ms. Giuffre that outweighs any benefit. Such discovery is prohibited by the Federal…
…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…