gov.uscourts.nysd.447706.223.7.pdf PDF
…Page 1 of 3 EXHIBIT 7 Case 1:15-cv-07433-RWS Document 223-7 Filed 06/16/16 Page 2 of 3 Law Offices of G regory L. Poe PLLC The Executive building 1030 15th Street, N.W.…
…Page 1 of 3 EXHIBIT 7 Case 1:15-cv-07433-RWS Document 223-7 Filed 06/16/16 Page 2 of 3 Law Offices of G regory L. Poe PLLC The Executive building 1030 15th Street, N.W.…
… B Judgment delivered 22 July 2008. Specific disclosure – Litigation privilege – Cross-examination – When court could go behind affidavit of documents – Third party sought specific disclosure of documents – Litigation privilege…
…13 Q. Is says Epstein also trafficked Jane Doe #3 14 for sexual purposes to many other powerful men including 15 numerous prominent American politicians, powerful 16 business executives, foreign presidents, a well-known 17 prime minister and other world…
…pictured below, is the executive producer of a film starring2 none other than Alan Dershowitz3: Online film promotions claim the following: Indeed, a clip of Dershowitz’s starring role in the film is featured by its promotional website:4 2…
…“including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Prime Minister and other world leaders.” Plaintiff refused, claiming every applicable privilege, and additionally “because naming some such individuals would jeopardize her physical safety based on credible…
…and Law Enforcement are not news- gathering activities ........................................................................................................... 7 II. THE ABSOLUTE PRIVILEGE OF THE SHIELD LAW IS NOT APPLICABLE BECAUSE THERE WAS NO EXPECTATION OF CONFIDENTIALITY ..................... 9 …
…including subparts, in violation of Rule 33. Ms. Giuffre objects to Defendant’s Second Set of Discovery Requests to the extent they seek information that is protected by any applicable privilege, including but not limited to, attorney client privilege, work…
…to disclose her address under Local Rule 26.1 ...................... 8 VI. PLAINTIFF’S SUBSTANTIVE OBJECTIONS ARE UNRECOGNIZED AND MERITLESS ................................................................................................................. 9 A. Plaintiff’s privilege claims are not cognizable. ...............…
…Filed 01/05/24 Page 4 of 40 Ms. Giuffre objects to Defendant’s First Set of Discovery Requests to the extent they seek information that is protected by any applicable privilege, including but not limited to, attorney client privilege…
…Filed 03/23/16 Page 4 of 45 Ms. Giuffre objects to Defendant’s First Set of Discovery Requests to the extent they seek information that is protected by any applicable privilege, including but not limited to, attorney client privilege…
…not only descriptions of sexual abuse by Epstein, but also new allegations of sexual abuse by several other prominent individuals, “including numerous prominent American politicians, powerful business executives, foreign presidents, a well‐ known Prime Minister, and other world leaders,” as…
…reasons why You cannot answer fully and providing whatever information You do have about the unanswered portion. 16. With respect to any Documents withheld on the basis of a privilege, provide a log consistent with Local Rule 26.2. 17…
…other interrogatories, exceed the allowable twenty-five interrogatories. Ms. Giuffre objects in that it seeks information protected by the attorney-client privilege, work product protections, and any other applicable privilege or protection as stated in the General Objections. Ms. Giuffre…
…1 at 5), while simultaneously submitting 14,825 pages of relevant materials under seal to the Court. The Government claimed that these pages were “privileged” for various reasons, attaching an abbreviated privilege log. Jane Doe No. 1 and Jane No…
…13 Q. Is says Epstein also trafficked Jane Doe #3 14 for sexual purposes to many other powerful men including 15 numerous prominent American politicians, powerful 16 business executives, foreign presidents, a well-known 17 prime minister and other world…
…Filed 03/31/16 Page 4 of 45 Ms. Giuffre objects to Defendant’s First Set of Discovery Requests to the extent they seek information that is protected by any applicable privilege, including but not limited to, attorney client privilege…
…Filed 03/23/16 Page 4 of 40 Ms. Giuffre objects to Defendant’s First Set of Discovery Requests to the extent they seek information that is protected by any applicable privilege, including but not limited to, attorney client privilege…
…not only descriptions of sexual abuse by Epstein, but also new allegations of sexual abuse by several other prominent individuals, “including numerous prominent American politicians, powerful business executives, foreign presidents, a well‐ known Prime Minister, and other world leaders,” as…
…not only descriptions of sexual abuse by Epstein, but also new allegations of sexual abuse by several other prominent individuals, “including numerous prominent American politicians, powerful business executives, foreign presidents, a well‐ known Prime Minister, and other world leaders,” as…
…not only descriptions of sexual abuse by Epstein, but also new allegations of sexual abuse by several other prominent individuals, “including numerous prominent American politicians, powerful business executives, foreign presidents, a well‐ known Prime Minister, and other world leaders,” as…
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