…DUPLICATIVE AND NO GOOD CAUSE EXISTS FOR PERMITTING ADDITIONAL DEPOSITION TIME ...... 10 III. COUNSEL INSTRUCTED MAXWELL NOT TO ANSWER TO ENFORCE THE COURT’S ORDER AND TO PREVENT HARASSMENT BY PLAINTIFF’S COUNSEL .........................................................................................................…
…their demands. For 3 Defendant’s counsel asked the following highly personal and irrelevant information as follows: Personal current financial information from this non-party which information is being sought only for the purposes of harassment. The witness…
…These arguments were made, and documents filed, for purposes of distraction and harassment, and have nothing to do with the issues presented by the motion. This is classic abuse of the courts records and files. The Response and Exhibits were…
…DUPLICATIVE AND NO GOOD CAUSE EXISTS FOR PERMITTING ADDITIONAL DEPOSITION TIME ...... 10 III. COUNSEL INSTRUCTED MAXWELL NOT TO ANSWER TO ENFORCE THE COURT’S ORDER AND TO PREVENT HARASSMENT BY PLAINTIFF’S COUNSEL .........................................................................................................…
… This Discovery is Barred by FRE 412......................................................20 2. This Request if Propounded for Improper Purposes and Harassment ......21 3. This Request Seeks Irrelevant Information ..............................................22 …
…7 1. The Qualified “Self-Defense” Privilege Does Not Protect The Publication Of Deliberately False Statements......................................8 2. The Qualified Pre-Litigation Privilege Does Not Protect Mass Publication Of D…
…These arguments were made, and documents filed, for purposes of distraction and harassment, and have nothing to do with the issues presented by the motion. This is classic abuse of the courts records and files. The Response and Exhibits were…
…and in media interviews and then in press-releases disguised as legal pleadings which she shared with the press. Faced with unrelenting negative press and harassment by the media in the United Kingdom spurred by Giuffre’s false claims, Ms…
…s.Giu ffre has performed an enormou s u nd ertakingto procu re over250 pages of med icalrecord s from over20 provid ers .A tthis point,D efend ant’s continu ed d iscoveryrequ ests are nothingmore than harassment. C…
…April 4, 2011) (trial court granting protective order precluding a deposition noting “this deposition request is mere harassment” and had no relevance to the underlying dispute where the party was wrongfully using the discovery process for personal gain). b. Category…
…See Lytle, 810 F. Supp. 2d 616 at 626 (refusing to redact names of targets of harassment and discrimination complaints even though “conduct at issue may be potentially embarrassing to these employees”); see also Bernsten v. O’Reilly, 307 F…
…prostitute I have been the target of outright lies, innuendo, slander, defamation and salacious gossip and harassment; headlines made up of quotes I have never given, statements I have never made, trips with people to places I have never been…
…not to mention the purposes of harassment. 12 Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 14 of 45 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) Pursuant to…
…protecting deponent from annoyance, embarrassment and harassment by denying party’s attempt to obtain personnel records relating to non-party). Courts are more vigilant with these protections when the discovery is being sought from a non-party. “[T]he fact…
…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 that 25 …
…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 that 25 …
…Judge Nathan squarely rejected the defense’s argument that “anonymity is necessary to protect its witnesses from scrutiny and harassment because of the significant publicity this case has garnered” because “these generalized concerns are present in every high-profile criminal…
…protecting deponent from annoyance, embarrassment and harassment by denying party’s attempt to obtain personnel records relating to non-party). Courts are more vigilant with these protections when the discovery is being sought from a non-party. “[T]he fact…
… see also DE 339 at 13-24 (detailing the record support for the argument that defense “counsel instructed Maxwell not to answer to enforce the Court’s Order and to prevent harassment by plaintiff’s 3 Case 1:15…
…Request in that it represents a complete invasion of privacy. A non-party should not be subjected to undue harassment serving no admissible purpose. 9 Without waiving such objections, a copy of non-party Sarah Ransome’s current passport…
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