…CONTINUING INSISTENCE ON, AND REPETITION OF, ACCUSATIONS AGAINST PROFESSOR DERSHOWITZ..............................................................5 III. THE EXCULPATORY EMAILS, REPLY BRIEF, AND MANUSCRIPT ..................................................…
…publicly disclosed volumes of information related to her allegations, to claim that letters or emails from her lawyers or other documents sent to any law enforcement agency are protected by any privilege. Plaintiff lacks standing to raise the issue and …
…AND REPETITION OF, ACCUSATIONS AGAINST PROFESSOR DERSHOWITZ..............................................................5 III. THE EXCULPATORY EMAILS, REPLY BRIEF, AND MANUSCRIPT ..............................................................................................6…
…deposition will not exceed a total of four hours. The two separate issues relate to (1) Defendant’s failure to answer certain questions at her deposition and (2) her late production of important emails. These two issues developed as follows. …
…production from Defendant's electronic media. Accordingly, please use IMAP Capable software (or a functional equivalent) to capture all of the sent/received emails from Ms. Maxwell's various email accounts, including but not limited to the following: (1) GMaxl…
…the Protective Order in giving testimony and producing documents including evidence of assault, medical records, and emails,” and “[t]hird-party witnesses have done the same.” Doc.892, at 6-7. “Protection of confidential discovery in this case is appropriate,”…
…in the event of an unsealing order, to permit the release of certain emails to avoid a situation where selective and one-side unsealing of deposition testimony occurs, and information is released in a manner that is decontextualized and unfair…
…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 and attachments that the parties previously designated confidential (RANSOME_000273-557) (“the Emails”)…
…matter was deemed fully c submitted. ·. II. The J?riv;i.l.ege Claim$ at l$l?rie : Defendant has withheld 99 pages of emails with communications involving various combinations of Brett Jaffe, Esq. ("Jaffe"), Mark Cohen, Esq. …
…7-9. 1. Mr. Dershowitz moved to unseal portions of a brief filed in connection with a motion to quash, discrete emails filed with the motion, and the manuscript of Ms. Giuffre’s memoir filed with another motion. Doc.364…
…and production from Defendant's electronic media. Accordingly, please use IMAP Capable software (or a functional equivalent) to capture all of the sent/received emails from Ms. Maxwell's various email accounts, including but not limited to the following: (1) …
…records and bank account numbers; (ii) personally identifiable information, such as a social security numbers, home addresses, personal email addresses or personal telephone numbers; (iii) protected health information, inclusive of physical and mental health records; and (iv) identifying information of…
…August 2016, Intervenor Alan Dershowitz ("Dershowitz") requested unsealing of portions of a brief filed in connection with a motion to quash, discrete emails filed with the motion, and the manuscript of Giuffre 's memoir filed with another motion. See ECF…
… Case 1:15-cv-07433-LAP Document 165-1 Filed 05/26/16 Page 2 of 6 Log Privilege …
…Filed 05/20/16 Page 1 of 6 EXHIBIT G Case 1:15-cv-07433-LAP Document 156-7 Filed 05/20/16 Page 2 of 6 Unidentified "Professionals" Log Email Sent …
…Specifically, I seek to unseal portions of a brief (the “Reply Brief”) and certain emails (the “Emails”) that were submitted in connection with a motion to quash a testimonial subpoena directed to British tabloid journalist Sharon Churcher, and a draft…
…During the course of my representation of Professor Dershowitz, I have on various occasions exchanged information via email with Ms. Maxwell’s counsel Laura Menninger. These emails are attorney work product because the information we exchanged implicates my or …
…obligations1. Indeed, in response to thirty-eight (38) requests for production, the defendant has chosen to produce two emails.2 This represents a willful disregard of her discovery obligations, something this Court should not condone. “Although not unlimited, relevance, for…
…on June 2, Plaintiff’s counsel sent an email that they had received “an email yesterday from Mr. Brunel's attorney saying he needs to reschedule. I believe he is trying to get us new dates today or tomorrow.” Id…
…York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S MOTION TO COMPEL DATA FROM DEFENDANT’S UNDISCLOSED EMAIL ACCOUNT AND FOR AN ADVERSE INFERENCE INSTRUCTION Plaintiff, Virginia …