giuffre-maxwell
gov.uscourts.nysd.447706.898.0
4 pg
…The Newspapers are aware of the general privacy interests at stake in this case, and that
the parties and witnesses relied on the existence of the protective orders in place when providing
testimony and evidence in discovery. See ECF No…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.33
24 pg
…the lesser sanction of striking the claim or precluding evidence
only on the damages that relate to the withheld documents and information. The information
being withheld – medical and psychological providers and their records – related directly to the
claims for physical…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.1_2
24 pg
…the lesser sanction of striking the claim or precluding evidence
only on the damages that relate to the withheld documents and information. The information
being withheld – medical and psychological providers and their records – related directly to the
claims for physical…
giuffre-maxwell
gov.uscourts.nysd.447706.63.0
22 pg
…and the attorney who objects must
sign any objection. This requirement is critical because ‘interrogatories serve not only as a
discovery device but as a means of producing admissible evidence; there is no better example of
an admission of a…
giuffre-maxwell
1320-33
24 pg
…the lesser sanction of striking the claim or precluding evidence
only on the damages that relate to the withheld documents and information. The information
being withheld – medical and psychological providers and their records – related directly to the
claims for physical…
giuffre-maxwell
gov.uscourts.nysd.447706.892.0
11 pg
…access for criminal investigative purposes civil
deposition transcripts taken under 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 …
giuffre-maxwell
gov.uscourts.nysd.447706.354.0
40 pg
…no relation to the subject matter
of this case, from decades in the past, are … not calculated to lead to the discovery of admissible
evidence” (emphasis supplied). As already discussed, the interrogatory requested information
about Plaintiff’s and her…
giuffre-maxwell
gov.uscourts.nysd.447706.231.0
23 pg
…the lesser sanction of striking the claim or precluding evidence
only on the damages that relate to the withheld documents and information. The information
being withheld – medical and psychological providers and their records – related directly to the
claims for physical…
giuffre-maxwell
gov.uscourts.nysd.447706.156.1
26 pg
…and
Work
[email protected],bra …
giuffre-maxwell
gov.uscourts.nysd.447706.1326.3
27 pg
…and
Work
[email protected],br …
giuffre-maxwell
gov.uscourts.nysd.447706.1320.15
27 pg
…and
Work
[email protected],br …
giuffre-maxwell
gov.uscourts.nysd.447706.1156.0
35 pg
…Argument About Her Right to a Fair Criminal Trial Was Raised
and Rejected on Appeal. ...............................................................................................8
IV. Maxwell’s Argument Concerning Potential Evidence at Her Criminal Trial
Was Raised on Appeal and is Irrelevant to t…
giuffre-maxwell
gov.uscourts.nysd.447706.156.3
9 pg
…Work Product/joint
2/16/2015 [email protected],robiej defense/common
2 1:05 [email protected] [email protected] Discussion of evidence among client and attorneys interest Wit…
giuffre-maxwell
gov.uscourts.nysd.447706.991.1
48 pg
…Protective Orders and Court Orders (“Motion to Compel”)
2. Motions in Limine re. Admissibility of Evidence and Related Orders (“Motion in Limine re.
Admissibility of Evidence”)
3. Motions in Limine re. Expert Testimony and Related Orders (“Motion in Limine re…
giuffre-maxwell
1320-15
27 pg
…and
Work
[email protected],br …
giuffre-maxwell
gov.uscourts.nysd.447706.993.0
28 pg
…TO COMPEL AND RELATED MOTIONS FOR
PROTECTIVE ORDERS AND COURT ORDERS ...................................................... 3
II. CATEGORY 2: MOTIONS IN LIMINE RE ADMISSIBILITY OF EVIDENCE
AND RELATED ORDERS .........................................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.165.1
6 pg
…overly
broad and unduly burdensome, as individually logging all
privileged responsive documents would be over…
giuffre-maxwell
gov.uscourts.nysd.447706.156.7
6 pg
…burdensome, as
individually logging all privileged responsive
documents would be overly burdensome. Plaintiff
…
giuffre-maxwell
gov.uscourts.nysd.447706.986.0
60 pg
…Preska
September 18, 2019
Page |2
2. Motions in Limine re. Admissibility of Evidence and Related Orders (“Motion in Limine
re. Admissibility of Evidence”)
3. Motions in Limine re. Expert Testimony and Related Orders (“Motion in Limine re.
Expert”)
4…
giuffre-maxwell
gov.uscourts.nysd.447706.1329.0
3 pg
…51 (2d Cir. 2019) (explaining the same).
This Document is akin to a summary exhibit under Federal Rule of
Evidence 1006 — a mere aid prepared by the parties to assist the
Court in carrying out its work. It includes the…