… 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…
…email correspondence). On June 9, 2016, undersigned counsel reiterated that position, asserted the Fifth Amendment privilege again, and stated objections to the Subpoena in a letter to plaintiff’s counsel. See Poe Decl., Exhibit 7 (letter from G. Poe to…
…Churcher ............................................................................................. 5 ARGUMENT .................................................................................................................................. 6 I. THE SUBPOENA SEEKS DOCUMENTS THAT ARE PRIVILEGED …
…the 25 interrogatory limit set by Rule 33. 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…
…the 25 interrogatory limit set by Rule 33. 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…
…III. The Applicable Standard Pursuant to Federal Rule of Civil Procedure 4 5 ( c) ( 3) (A), a court "must quash or modify a subpoena that (iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies…
…the 25 interrogatory limit set by Rule 33. 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…
…the 25 interrogatory limit set by Rule 33. 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…
…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…
…1 B. Ms. Maxwell’s Statement In Context Is Not Defamatory ................................... 3 II. MS. MAXWELL’S STATEMENTS ARE PROTECTED BY PRIVILEGE .......... 6 A. Qualified Privilege May Form the Basis for a Rule 12(b)(6) Dismissal ............. 6 B. Ms. Maxwell…
…150 East 10th Avenue Denver, CO 80203 Tel: 303.831.7364 Dated: November 30, 2015 …
…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…
…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…
…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…
…of this action. Plaintiff and her attorney’s communications with the media are directly relevant to numerous defenses available to Ms. Maxwell, including without limitation, her self-defense privilege, whether Plaintiff is a limited public figure, Ms. Maxwell’s right…
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