…or alluded to in Your Complaint, or any that could be included in any amended complaint in this action. 7. “Employment” includes without limitation, the provision of work and/or services, whether paid or unpaid, whether as an employee, intern…
…using multiple different email accounts. See Churcher Decl. ¶ 10.7 Moreover, as discussed above, much of Ms. Churcher’s communications with and about Ms. Roberts involved information that Ms. Churcher received in confidence. Even if those communications were not protected…
…potions, discussed below, is met – the information is highly relevant, critical to the defense, and available form no other source. 5 Case 1:15-cv-07433-LAP Document 1325-1 Filed 01/04/24 Page 8 of 21 C…
…Page 1of2 United States District Court Southern District of New York VIRGINIA GIUFFRE, Plaintiff, v. usuc . …
…Laura A. Menninger of the law firm Haddon, Morgan and Foreman, P.C., hereby respectfully submits the recent decision in Hill v. Cosby, 15 cv 1658 (W.D. Pa. January 21, 2016). In Hill v. Cosby, the court dismissed, with…
…15-cv-07433-RWS Document 916 Filed 05/24/17 Page 1 of 2 United States District Court Southern District of New York VIRGINIA GIUFFRE, Plaintiff, Case No.: 15-cv-07433-RWS v. GHISLAINE MAXWELL, …
…way. These Documents should include, without limitation, any witness statements, including statements made by You. 23 Case 1:15-cv-07433-LAP Document 1320-37 Filed 01/03/24 Page 25 of 48 Response to Request No. 3 Ms…
…way. These Documents should include, without limitation, any witness statements, including statements made by You. 23 Case 1:15-cv-07433-LAP Document 1331-3 Filed 01/05/24 Page 25 of 48 Response to Request No. 3 Ms…
…Documents should include, without limitation, any witness statements, including statements made by You. Response to Request No. 3 19 Case 1:15-cv-07433-RWS Document 71-2 Filed 03/23/16 Page 21 of 45 Ms. Giuffre objects…
…Documents should include, without limitation, any witness statements, including statements made by You. Response to Request No. 3 19 Case 1:15-cv-07433-LAP Document 76-1 Filed 03/31/16 Page 21 of 45 Ms. Giuffre objects…
…way. These Documents should include, without limitation, any witness statements, including statements made by You. 23 Case 1:15-cv-07433-LAP Document 1320-37 Filed 01/03/24 Page 25 of 48 Response to Request No. 3 Ms…
…way. These Documents should include, without limitation, any witness statements, including statements made by You. 23 Case 1:15-cv-07433-LAP Document 235-3 Filed 06/21/16 Page 25 of 48 Response to Request No. 3 Ms…
…hereby respectfully submits this Memorandum of Law in support of her Motion to Stay Discovery during the pendency of her Motion to Dismiss. LEGAL STANDARD Rule 26(c) of the Federal Rules of Civil Procedure grants courts broad discretion to…
…for an Order pursuant to Federal Rule of Civil Procedure 12(b)(6) dismissing the Complaint of Plaintiff Virginia Giuffre in its entirety and granting such other and further relief as the Court deems just and proper. Dated: November 30…
…line, paragraph and page of the Sealed Materials. For reasons having to do with the legal bases for sealing and redacting non-judicial and judicial documents, discussed later in this letter, this was not a project that could be performed…
…or in the metadata, in other words hundreds of thousands of non-responsive documents. Your search terms include “bill” and thus are likely to include every bill that our client has received or sent or discussed. Your search terms include…
…or in the metadata, in other words hundreds of thousands of non-responsive documents. Your search terms include “bill” and thus are likely to include every bill that our client has received or sent or discussed. Your search terms include…
…10/19 Page 2 of 2 The Honorable Loretta A. Preska July 10, 2019 Page 2 concerns about the procedures discussed in the opinion, particularly as those procedures apply to this action. Modification or vacatur of the opinion by the…
…of little concern here. The Court, of course, would not permit a non-party to manipulate the process prescribed by the Protocol to file multiple objections or otherwise to create undue delay. This is not such a circumstance. As discussed…
…Rule 37(b) of the Federal Rules of Civil Procedure provides that the court may impose a range of sanctions, including dismissal or judgment by default, preclusion of evidence, imposition of an adverse inference, or assessment of attorneys' fees and…
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