…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. ..............................................…
…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…
…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…
…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 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…
…memoranda, witness interviews, and other material’” created in preparation for litigation and trial (emphasis added) (internal citation omitted)). Indeed, “protection of witness interviews has been one of the focuses of the attorney 21 relevance of the questions were tenuous at…
…memoranda, witness interviews, and other material’” created in preparation for litigation and trial (emphasis added) (internal citation omitted)). Indeed, “protection of witness interviews has been one of the focuses of the attorney 21 relevance of the questions were tenuous at…
…D. 384, 391 (S.D.N.Y.2015). b. Work Product Privilege The work-product privilege protects documents either created by counsel or at counsel's directive, in anticipation of litigation. See In re Grand Jury Subpoenas Dated March 19…
…shall be produced in its native form; that is, in the form in which the information was customarily created, used and stored by the native application employed by the producing party in the ordinary course of business. 8. Defendant does…
…by the way, and which we have to assume provide the contours of 3 the information they are seeking in deposition, were created or 4 obtained by Ms. Churcher in the course of her news-gathering 5 activities, and much…
…admitted that she waived her work product privilege with regard to Barden’s alleged legal strategy, “intent,” and the like. The documents Barden created and considered (including drafts) should be produced, because their protection has been waived, as Defendant - admits. …
…D. 384, 391 (S.D.N.Y.2015). b. Work Product Privilege The work-product privilege protects documents either created by counsel or at counsel's directive, in anticipation of litigation. See In re Grand Jury Subpoenas Dated March 19…
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