….............. 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…
…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…
…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…
…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…
…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. …
…or documents concerning any police reports, that were created concerning such claims of sexual assault; and (3) documents concerning any communications received by You (or Your agents or attorneys) by other individuals that reference any sexual assault of Plaintiff while…
…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. …
…beggars belief. No document has ever been contemplated, created nor lawyer nor other approached to write such a document at anytime THE TERRAMAR PROJECT FACEBOOK TWITTER G+ PINTEREST INSTAGRAM PLEDGE THE DAILY CATCHthe From: J Jep Date: Wednesday, April 22…
…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. …
…be considered to be within thc relevant time frame ifit refers or relates (0 communications, meetings or other events or DoclIments that occurred or were created \vithill that time frame, regardless of the date of creation of the responsive Document. …
…Patterson. 32. All manuscripts and/or other writings, whether published or unpublished, created in whole or in part by or in consultation with You, concerning, relating or referring to Jeffrey Epstein, Ghislaine Maxwell or any of their agents or associates…
…outstanding document requests that were issued in her Second Request for Production. Finally, the forensic examination would be performed at a time and in a manner that created no disruption for Defendant, so Defendant has no significant countervailing interests to …
…s 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. C. Ms. Giuffre Did Not Oppose the Relief…
…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…
…Mr. Rodriguez is a convicted criminal, and was convicted for obstruction of justice based on the very testimony Plaintiff seeks to admit. He either created evidence to use in those proceedings, or he hid evidence in them. Either way, his…
…. could mitigate the burden . . . including . . . exclusion from the privilege logs of documents created after the commencement of litigation . . ..”) (emphasis added). See also United States v. Bouchard Transp., No. 08-CV-4490 NGG ALC, 2010 WL 1529248, at *2 (E.D…
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