…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…
…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…
…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…
…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 All manuscripts and/or other writings, whether published or unpublished, created in whole or in part by you, concerning, relating or referring to Jeffrey Epstein and any of his agents or associates. 24.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…
…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…
…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…
…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…
…MENNINGER: Your Honor, on this particular one, 6 she says her client does not have any nonprivileged documents 7 created during the time period responsive to this request, and 8 then there are no privileged documents related to this log…
…05/24 Page 9 of 22 standard of truth 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…
…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…
…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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