…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…
…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 …
…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…
…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…
… 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 …
…9, 2016 Order. The Court is now in possession of three additional documents that Defendant failed to produce in contravention of this Court’s Order, in addition to the emails (emails that included among them that Defendant wrongfully withheld. So…
…173-4, 173-10, which Maxwell argues are not judicial documents because they contain “various back and forth emails between counsel.” Maxwell Mem. at 11-12. These docket entries are already available to the public in full on the docket…
…there were many documents where there was only a single item on a page was redacted, e.g., a surname or an email address; there were other documents where on a single page various phrases, sentences or paragraphs were redacted…
…should not be filed publicly with Doe 1’s name unredacted. (See Def. Letter at 2.) The Court has already declined to construe the emails from Does 1 and 2 that Defendant refers to as formal objections (Order, dated Oct…
…without 24 marking it as confidential. So I sent them an email just 25 asking them to hold that as confidential until the Court has an SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 Case 1:15-cv-07433…
…camera review, Defendant and Mr. Gow previously exchanged emails about how to leak information to the press to discredit Ms. Giuffre by saying that she “cried rape” when she was 14 (GM_00577): From: Ross Gow Sent: Tuesday, February 24…
…Second, these agreements are plainly relevant to the defamation claim in this case. This Court has previously ordered Defendant to produce emails in which both Epstein and Dershowitz were active in assisting Defendant draft defamatory statements against Ms. Giuffre. See…
…Filed 05/20/16 Page 1 of 9 EXHIBIT C Case 1:15-cv-07433-LAP Document 156-3 Filed 05/20/16 Page 2 of 9 Pottinger Documents Log Email Sent …
…II”).) DE 173, a declaration, references additional Non-Parties, generally those identified in lawyer emails. The Court may wish to defer consideration of this DE. Redaction of the names would eliminate any issue related to this document. DE 173-1…
…that is vital to his defense – the third prong in the tri-part test. To date, Plaintiffs have hidden behind the attorney-client privilege to selectively produce evidence regarding their conversations, emails, and/or interviews with Giuffre. As noted above…
…difficult to deem communications that predominantly address a press statement as legal advice.”2 Id. at 20. It is apparent from the documents logged by Plaintiff that communications contained in her emails “amounts to public relations, not legal, advice.” Id…
…a protective order). In this case , the parties and multiple deponents have reasonably relied on the Protective Order in giving testimony and producing documents including evidence of assault , medical records , and emails . See Med . Diagnostic Imaging, PLLC v . Carecore Nat .…
Case 1:15-cv-07433-LAP Document 986 Filed 09/18/19 Page 1 of 60 Sigrid McCawley Telephone: (954) 356-0011 Email…
… Case 1:15-cv-07433-LAP Document 156-1 Filed 05/20/16 Page 2 of 26 Log Privilege Doc ID…