…proceed with a VI deposition and to accept service for that deposition. I understand the issue expressed below and will prgmptly communicate with Ms Maxwell's counsel in order to determine her position. Thanks, Marty From: Sigrid McCawley Sent: Thursday…
…of harassment. Ms. Ransome has expressed fear for her life in deciding to present herself and her testimony publicly against Jeffrey Epstein and the Defendant. She contends she has already been followed from her home by two male persons. This…
… It's -- you're 11 seeking information to be able 12 to -- the witness has already 13 expressed fear about her -- 14 people currently going after her. 15 So we would object to that 16 intimidation of a nonparty 17…
…the Second Circuit, we believe her participation and the participation of other third parties whose privacy interests are implicated are appropriate. Ms. Campbell expressed interest in participating in the post-remand proceedings, and does not oppose adjournment of the conference.
…delete it from your system. Please be advised that the views and opinions expressed in this e-mail may not reflect the views and opinions of Associated Newspapers Limited or any of its subsidiary companies . We make every effort to…
…claim of privilege under this statute, the information must be imparted to the reporter under a ‘cloak of confidentiality’. There had to be an understanding, express or implied, that the information will not be disclosed” People v. Bova, 118 Misc…
…description, Ghislaine Maxwell. 29. All Documents concerning any Communications by You or on Your behalf with any media outlet, including but not limited to the Daily Mail, Daily Express, the Mirror, National Enquirer, New York Daily News, Radar Online, and…
…Id. And New York courts have pointed out that the legislature’s express purpose in passing the Shield Law was “to avoid ‘problematic incursions into the integrity of the editorial process ….’” In re Grand Jury Subpoenas Served on NBC…
…her family's location, 19 things of that nature. 20 The witness has expressed to 21 me fears of harassment and the 22 belief that she's being followed, 23 and my understanding is that 24 there are other witnesses…
…her family's location, 19 things of that nature. 20 The witness has expressed to 21 me fears of harassment and the 22 belief that she's being followed, 23 and my understanding is that 24 there are other witnesses…
…At any time, on notice to the commanded person, die serving party (i) expressly make the daim; and may move the cour1 for the district where compliance is ~uired for an (ii) d=ibc the nature of the withheld documents, communications…
…used appropriately broad, but tailored search terms, including, but not limited to the names of the individuals expressly listed in Plaintiff’s Requests for Production as well as the e-mail addresses of those individuals, if known. Ms. Maxwell is…
…withheld based on any alleged privilege or protection: (A) Information Withheld. A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and (ii) describe…
…D. Kan. 1996) (“Identification of individuals pursuant to Fed.R.Civ.P. 26(a)(1) includes providing their addresses and telephone numbers, if known. The rule expressly states as much.”); Fausto v. Credigy Svcs. Corp., 251 F.R.D. 427…
…agreement to proceed with a VI deposition and to accept service for that deposition. I understand the issue expressed below and will promptly communicate with Ms Maxwell's counsel in order to determine her position. Thanks, Marty From: Sigrid McCawley …
… It's -- you're 11 seeking information to be able 12 to -- the witness has already 13 expressed fear about her -- 14 people currently going after her. 15 So we would object to that 16 intimidation of a nonparty 17…
…withheld based on any alleged privilege or protection: (A) Information Withheld. A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and (ii) describe…
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