…L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S MOTION TO EXCLUDE DEFENDANT’S DESIGNATION OF DEPOSITION EXCERPTS OF ALAN DERSHOWITZ IN AN UNRELATED CASE …
…HAS WAIVED ANY ARGUMENT AS TO CONFIDENTIALITY ................ 9 A. Plaintiff Failed to Timely Move this Court to Uphold Her Designation of the Documents as Confidential ................................................................................................................. 9 B. Plaintiff’s Counsel Has …
…if the Court allows Plaintiff Virginia Giuffre to remove the confidentiality designation concerning the Ransome deposition—an action that would require modification of the Protective Order in this case —it also simultaneously remove the confidentiality designation from several related emails…
…the parties unrestricted authority to disclose publicly the confidential materials from Maxwell--not least of all because the parties only may agree to downgrade confidentiality designations for materials that the “designating party has subsequently produced in this action,” i.e.…
… 2. It defines Confidential Information to include, inter alia, “information filed under seal or designated as ‘Confidential’ in another action for which the confidentiality designation or seal has not been lifted.” Id. Thus, “Confidential Information” encompasses sealed information from Maxwell…
…HAS WAIVED ANY ARGUMENT AS TO CONFIDENTIALITY ................ 9 A. Plaintiff Failed to Timely Move this Court to Uphold Her Designation of the Documents as Confidential ................................................................................................................. 9 B. Plaintiff’s Counsel Has …
…just such a reservoir for her profit motives. IV. Category 4: Trial deposition designations and counter-designations. The parties designated and counter-designated many hundreds of pages from deposition transcripts. Such designations are made routinely under Rule 32(a)(6…
…A. The Protective Order included a mechanism for one party to challenge another party’s confidentiality designation (such a challenge never occurred) and provided that it did not apply to any information or material disclosed at trial. (Because the case…
…and deponents reasonably relied on protective order); DE 1062 at 3-6 (protective order tracks permissible scope under Rule 26(c)(1), includes provisions to challenge improper designation of confidentiality, contained no temporal limit, and appropriately limited use of confidential…
…as deserving of protection. Contrary to Dershowitz’s assertions, the Protective Order also includes mechanisms to ensure that confidentiality designations are justifiable. See Section 8 (stating that designation of information as confidential constitutes a representation by the attorney for the…
…could be obtained by a simple visit to the Department of Motor Vehicles. Any newfound privacy concerns can be alleviated by a “confidential” designation on the production. 2 Ms. Ransome testified that she was “followed at least once,” but that…
…could be obtained by a simple visit to the Department of Motor Vehicles. Any newfound privacy concerns can be alleviated by a “confidential” designation on the production. 2 Ms. Ransome testified that she was “followed at least once,” but that…
…is patently frivolous. (Pl’s M. Compel at 10). Likewise, her designation of Mark Cohen as a “non-attorney” (id. at 9) is similarly frivolous. Further, Plaintiff submitted to the Court in Opposition to the Motion to Dismiss, a cease…
…Supp. 2d 318, 341 (S.D.N.Y. 2003) (granting modification of protective order where stipulated order “allowed for unilateral designation of an exhibit as protected material, and it did not list specific documents, or delineate the kinds of documents…
…Southern District of Florida, 08-cv-80736-KAM pleadings to include: a. Motion for Limited Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic Filing (July 28, 2008) (Doc. # 16) b. Notice of Change of Address and…
…the designations in correspondence have been modified here – as indicated by brackets – to track the current designation in the pleadings. 4 Case 1:15-cv-07433-LAP Case 9:08-cv-80736-KAM Document Document 1137-15 …
…by contrast, the USVI does not know who has testified in depositions that are sealed or otherwise shrouded by confidentiality designations. This is why the highlighted 5 Case 1:15-cv-07433-LAP Document 1122 Filed 09/24/20…
…Southern District of Florida, 08-cv-80736-KAM pleadings to include: a. Motion for Limited Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic Filing (July 28, 2008) (Doc. # 16) b. Notice of Change of Address and…
…to portions of these and other depositions designated by Plaintiff. She further states as follows: INTRODUCTION Plaintiff has filed deposition designations for 14 witnesses for use in her case in chief at trial. With respect to four of the witness…
…the documents designated as “confidential” under the Protective Order have not been individually scrutinized by this Court to determine whether the designation is proper and/or that they are truly entitled to confidential treatment under the law in this Circuit. …
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