…CONTINUING INSISTENCE ON, AND REPETITION OF, ACCUSATIONS AGAINST PROFESSOR DERSHOWITZ..............................................................5 III. THE EXCULPATORY EMAILS, REPLY BRIEF, AND MANUSCRIPT ..................................................…
…THE SUBPOENA TO APPLE, INC. SEEKING PRODUCTION OF ALL OF MS. GIUFFRE’S SENT AND RECEIVED EMAILS AND RELATED DATA Plaintiff Virginia Giuffre, by and through her undersigned counsel, hereby files this motion for a protective order, barring enforcement of…
…2. Terramar – You have withdrawn that as a standalone search term. I have represented to you that we have searched all Terramar emails for otherwise responsive documents as well as 3. Witness names – You believe that search terms 124-341…
…past and ongoing legal matters both before and after April 2015. I regularly communicated with Mr. Epstein regarding my legal representation of him via email with the intention that such email communications remain confidential and privileged. As counsel for Mr…
…AND REPETITION OF, ACCUSATIONS AGAINST PROFESSOR DERSHOWITZ..............................................................5 III. THE EXCULPATORY EMAILS, REPLY BRIEF, AND MANUSCRIPT ..............................................................................................6…
…Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S MOTION FOR A PROTECTIVE ORDER REGARDING THE SUBPOENA TO MICROSOFT CORPORATION SEEKING PRODUCTION OF ALL OF MS. GIUFFRE’S SENT AND RECEIVED EMAILS AND RELATED DATA Plaintiff Virginia Giuffre, by and through her undersigned counsel…
…Up Flag Status: Flagged Laura, Please see my additions in-line, in black, below to your email sent yesterday. My in-line communication should also be responsive to the email that you just sent. If I have left anything out…
…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,”…
…for Production served on Ms. Maxwell, nor the Court’s Orders limiting those requests. Terramar – Search term 49 is “Terramar.” While we are searching our client’s terramar email address for otherwise responsive documents, this search term would pull up…
…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. …
…any person, group or entity. ...... 15 II. Ms. Maxwell properly has asserted privileges. ......................................................... 17 A. Email from Mr. Epstein to Ms. Maxwell. ................................................................ 17 B. Emails exchanged between Mr. Dershowitz…
…2 MS. MENNINGER: Your Honor, I actually believe that 3 these emails were some that your Honor had reviewed because we 4 had asserted a joint defense agreement privilege, and your 5 Honor reviewed these emails, and they were produced…
…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…