…process. At the July 26 meet and confer, Maxwell’s counsel expressed that they would be unable to carry out the Court’s suggestion due to scheduling conflicts until January of next year, and asserted 1 The Non-Party Objectors…
…ATTACHED IN 2011 WHEN SHE FORMED AN INTENT TO JOIN THE CVRA LITIGATION Plaintiff concedes she willfully and deliberately destroyed while she prepared to join the CVRA litigation and while she was represented by current counsel for that express purpose…
…50). But we agree. It would be legal error for a court to conclude that a given filing is non-judicial merely because the court did not expressly rely on that filing “in adjudicating a motion.” But, of course, that…
…SHE FORMED AN INTENT TO JOIN THE CVRA LITIGATION Plaintiff concedes she willfully and deliberately destroyed her journal in 2013 while she prepared to join the CVRA litigation and while she was represented by current counsel for that express purpose…
…press. Defendant repeatedly made that false statement despite the fact that the documents show that Defendant authorized the statement and gave express approval to her press agent to publish the press release – not Barden – with Barden nowhere to be found…
…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…
…than an answer to an interrogatory. See Fed.R.Civ.P. 33(c) (expressly authorizing the use of interrogatories at trial to extent permitted by the law of evidence). A response which is nothing more than a cross-reference by…
…and fundamental rights. Ms. Maxwell requests a pre-trial hearing on this issue and that the Court issues a ruling that the opinions expressed in Exhibit A are inadmissible at trial for the above stated reasons. Dated: January 5, 2017 …
…must be excluded. Ms. Maxwell requests a pre-trial hearing on this issue and that the Court issues a ruling that the opinions expressed in Exhibit A are inadmissible at trial for the above stated reasons. Dated: January 5, 2017 …
…than an answer to an interrogatory. See Fed.R.Civ.P. 33(c) (expressly authorizing the use of interrogatories at trial to extent permitted by the law of evidence). A response which is nothing more than a cross-reference by…
…This Court has received at least one email from a non-party’s counsel expressing dissatisfaction with the previous redactions because there were descriptions of conduct that would allow the identity of the given non- party to be surmised by…
…71 F.3d 1044, 1050 (2d Cir. 1995) (“Amodeo II”)). The Brown court expressly acknowledged the right of an accused as a “countervailing interest” worthy of overcoming any presumption of access. Id.at 47 n. 13. (“Examples of such countervailing…
…22. 23. January 3, 2015 Press Statement issued by Ross Gow to Express set forth in “Ghislaine Maxwell: I was not a madam for paedophile,” attached as Exhibit 23. 24. January 4, 2015 Statement by Ghislaine Maxwell to New York…
…Order. For example, Doe # 84 is an individual who testified at a deposition, represented by counsel, under the express promise of confidentiality under the Protective Order. This individual accused Mr. Epstein of wrongdoing perpetrated when the individual was minor. During…
…For example, Doe #84 did not receive notice and it is uncontested that Doe #84 testified only under the express promise of confidentiality. The Second Circuit sua sponte redacted Doe #84’s name from summary judgment pleadings finding that Doe…
…r private parties." Id. New York cour ts have pointed out that t h e legislat ure's express purpose in passing the Shield Law was " to avoid 'problematic incursions into the integrity of the ed i torial process.'" In…
…Therefore a finding of liability for [defamation] per se, coupled with an express finding that the [defamation] was intended to injure plaintiff and did in fact cause injury, authorizes the jury to consider and assess punitive damages without any finding…
…have sued Dershowitz for defamation after he alleged they should be disbarred for initially putting Roberts' allegations in court papers. "I am happy today to express my willingness to be deposed after the three of them are deposed," he said…
…have sued Dershowitz for defamation after he alleged they should be disbarred for initially putting Roberts' allegations in court papers. "I am happy today to express my willingness to be deposed after the three of them are deposed," he said…
…9 Case 1:15-cv-07433-RWS Document 509 Filed 12/09/16 Page 11 of 18 discovering party. See, Fujitsu Ltd. v. Federal Express Corp., 247 F.3d 423, 436 (2d Cir.2001); Zebulake v. UBS Warburg LLC…
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