…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”)…
…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…
…access.”). Tellingly, Ms. Giuffre does not even attempt to explain how the Emails or the Reply Brief could possibly constitute sensitive business information. Moreover, even if the Requested Documents could be considered private in another context, Ms. Giuffre long ago…
…Mccawley, Esq. E-mail : [email protected] September 16, 2016 VIA Email: [email protected] …
…See May 18, 2016 letter from J. Pagliuca ("Your email does not provide any good faith basis for the [confidentiality] assertion, likely because there is none."). I disagree. Your latest produc6on includes a police report detailing the rape of a…
…produce the document is groundless and the Court should order production of the document forthwith and sanction Plaintiff for her conduct. STATEMENT OF CONFERRAL The undersigned has conferred extensively with Plaintiff’s counsel on this issue by telephone and email…
…whatever 17 those documents are, photographs, whatever they are. 18 MR. MILLER: Photographs and e-mails. 19 THE COURT: Yes, okay. That's what we are talking 20 about. 21 MR. MILLER: It is a hundred percent what we are…
…Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: [email protected] [email protected] /s/ Sigrid S…
…Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: [email protected] [email protected] /s/…
…attorney-client privilege. See Menninger Decl., Ex. J, (email between Plaintiff and Sharon Churcher crafting communication to Edwards regarding publication of privileged communication). Yet, when the conversation was sent to the press, and used in later court filings, Plaintiff did…
…Ms. Maxwell, and her “joint defense partners,” have never “fed” to the media anything about Plaintiff’s various false claims of sexual abuse. To the contrary, all of the email exchanges between Ms. Maxwell, , Mr. Epstein and others indicate Ms…
…Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: [email protected] [email protected] /s/ Sigrid S.…