…wexner-israel-fellowship-program), which brings ten Israeli public officials to Harvard for a fully funded Master’s degree program in public administration at the Kennedy School of Government. With the participation of The Wexner Foundation, Republican pollster and rightwing…
…s accountability and legitimacy.” No. 14-CV-6867 (VEC), 2016 WL 1071107, at *9. “And the public has a right to know how its resources are being used—courts are funded by the public, . . . and the laws under which parties…
…Introduction Plaintiff cannot meet the merits of Ms. Maxwell’s well-founded objections to the release her July 2016 compelled deposition testimony or information concerning various Non-Parties, all of whom relied on the Protective Order issued by the Court…
…Motion for Sanctions (“Sur-Reply”), stating as follows: INTRODUCTION Plaintiff’s Response and Sur-Reply are founded entirely on a miscomprehension of the requirements of Federal Rules of Civil Procedure 26 and 33. She strenuously argues that she has “disclosed…
…Motion for Sanctions (“Sur-Reply”), stating as follows: INTRODUCTION Plaintiff’s Response and Sur-Reply are founded entirely on a miscomprehension of the requirements of Federal Rules of Civil Procedure 26 and 33. She strenuously argues that she has “disclosed…
…RWS Document 22 Filed 12/15/15 Page 2 of 14 Table of Contents ARGUMENT....................................................................................................................... 2 I. The Motion to Dismiss is Dispositive and Well Founded In Law ....................…
…acknowledge that the public filing in the Crime Victims’ Rights Act case of their client’s allegations against Defendant Dershowitz became a major distraction from the merits of the well-founded Crime Victims’ Rights Act case by causing delay and…
…present in her case-in-chief. Ms. Maxwell has filed well-founded motions in limine to exclude the testimony of both Dr. Kliman and Professor Coonan prohibiting from providing their credibility and vouching opinions. This is the subject matter of…
…1285 at 2. However, any assumptions the Court made were well founded, and the Court’s ultimate ruling was correct and should not be reconsidered. Doe 171’s motion asserts that she “maintains her right to remain anonymous,” yet her…
…do acknowledge that the public filing in the Crime Victims’ Rights Act case of their client’s allegation against Defendant Dershowitz became a major distraction from the merits of the well-founded Crime Victims’ Rights Act by causing delay and…
…7 (quotation marks and citation omitted). The Court concluded that Mr. Dershowitz’s proffered bases for modification – even if well-founded, which the Court rightly doubted – were beside the point: “That is all well and good, but while fostering judicial…
…the Sealed Materials, that alone is a violation of the Protection Order. As Plaintiff well knows, Ms. Maxwell was forced to answer substantial, numerous, ill- founded questions regarding her private life, her , her residences, her friends, and her living arrangements…
…Court addressed. Accordingly, the objection is well founded. Plaintiff’s tortured explanation about how the question fits into the Court’s Order is nonsense. 16 G. Objection to Question Number 8 “In terms of preparing for this deposition, what…
…The Terramar Project, that Ms. Maxwell founded and runs. Plaintiff’s originally proposed terms also failed to relate to the actual discovery requests upon which they were to be based. For search terms 124-341, Plaintiff took her own Rule…
…their client’s claims – were false. The Complaint by Edwards and Cassell alleged that “[i]mmediately following the filing of what Dershowitz knew to be an entirely proper and well- founded pleading, Dershowitz initiated a massive public media assault on…
…se by claiming 9 her profession is as a professional victim. In other words, 10 ten days before she claims my client made statements about her, 11 plaintiff founded a nonprofit through her organization, through 12 her attorneys in Florida…
…14 all avenues available to us to obtain this information. There 15 is really no place else to go. And so there is -- I think it 16 is not well founded, your Honor, that there is some notion that 17 …
…privilege. The conduct of the attorneys Edwards and Cassell that forms the basis for Dershowitz's counterclaim for defamation is nothing more than filing a well-founded motion in pending federal court proceedings on behalf of pro bono clients. In…
…their client’s claims – were false. The Complaint by Edwards and Cassell alleged that “[i]mmediately following the filing of what Dershowitz knew to be an entirely proper and well- founded pleading, Dershowitz initiated a massive public media assault on…
…the objection is well founded. Plaintiff’s tortured explanation about how the question fits into the Court’s Order is nonsense. 16 Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 19 of 27…
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