…a substantial financial interest in pursuing claims on behalf of its other clients against numerous other individuals and institutions related to Mr. Epstein’s Estate. In this sense, Boies Schiller may be laboring under a real conflict of interest in…
…claims of improper and unrecognized “privilege”; 2) assertion of improper protections from discovery claiming “proprietary” “copyright” and “confidentially” protection; 3) claims of invasion of “privacy” interests in financial, employment and medical information, all of which are put directly at issue…
…198 F.3d 317, 322-23 (2nd Cir. 1999) (“This Court has recognized the existence of a constitutionally protected interest in the confidentiality of personal financial information.”) (quoting Barry v. City of New York, 712 F.2d 1554, 1558–59 …
…198 F.3d 317, 322-23 (2nd Cir. 1999) (“This Court has recognized the existence of a constitutionally protected interest in the confidentiality of personal financial information.”) (quoting Barry v. City of New York, 712 F.2d 1554, 1558–59 …
…often would be prejudicial to a defendant to attempt to litigate its financial condition during the trial on the issues of liability and compensatory damages, the preferred method of accommodating the various interests is to delay trial as to the …
…to Enforce Court Order and Direct Defendant to Answer Depo Questions 370: Defendant’s Motion for Protective Order regarding Financial Information 335: Plaintiff’s Motion for Protective Order for Court to Direct Defendant to Disclose Individuals Whom Defendant…
…12 B. There Is No Risk of Undue Delay or Prejudice .........................................12 C. Professor Dershowitz Has a Compelling Interest in Access That Is Not Represented by Any Existing Party ........................................1…
…the interest of justice and to avoid any undue prejudice during the liability phase of this action, the trial will be bifurcated. . . . Therefore, defendant's motions for partial summary judgment and to stay discovery as to his financial status are…
…the interest of justice and to avoid any undue prejudice during the liability phase of this action, the trial will be bifurcated. . . . Therefore, defendant's motions for partial summary judgment and to stay discovery as to his financial status are…
…well-crafted with the assistance of high-priced attorneys to facilitate Giuffre’s media exposure, to enhance her marketability, to extract financial gain for herself and her family, and to promote her sham non-profit, Victims Refuse Silence, Inc. 2…
…Court, and/or that plaintiff submitted to the Court for no valid purpose. The Sealing Opponents’ reputational (Dershowitz) and financial (the other Opponents) interests are diametrically opposed to Ms. Maxwell’s and the non-parties’. Because of their respective motivations…
…as she poses to promote body positivity …
…access to the materials; (2), identify and evaluate the 14 weight of any countervailing interests; and (3) determine 15 whether the countervailing interests rebut the presumption. 16 The presumption of public access attaches to judicial 17 documents, those documents filed…
…Brown v. Maxwell, 929 F.3d 41, 47 n.13 (2d Cir. 2019) (noting that it is the “privacy interest of those who resist disclose” that serve as a countervailing interest) (quoting S.E.C. v. TheStreet.Com, 273 F…
…information protected by the attorney/client privilege, the work-product doctrine, Rule 408 of the Federal Rules of Evidence, any common interest privilege, joint defense agreement or any other applicable privilege. 4. Ms. Maxwell objects to the Interrogatories to the…
…all Financial Statements prepared for or submitted to any Lender or Investor for the past three years by You personally or on Your behalf or on behalf of any entity in which You hold or held a controlling interest from…
…22 b. Work Product Privilege has been Waived ......................................................................... 23 c. There is no basis to claim common interest or joint defense privilege .............................. 23 CONCLUSION ..................................................................................…
…the subpoena served on Ms. Ransome seeks documents that are wholly irrelevant to the underlying action including protected financial information and documents or communications between Sarah Ransome and her attorneys, which are protected by the attorney- client privilege and the…
… The Court Should Not Redact Information that is Already Public. .......................... 12 III. The Court Should Consider the Countervailing Interests of the Non-Parties Who Have Not Objected to Unsealing for Judicial Efficiency. .......................................................... 12 CONCLUSION .........…
…Relationship .......................................................................... 22 b. Work Product Privilege has been Waived ......................................................................... 23 c. There is no basis to claim common interest or joint defense privilege .............................. 23 CONCL…
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