…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 .........................................................................................................…
…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 .........................................................................................................…
…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…
…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…
…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 …
…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…
…The Privilege therefore protects "the independence of the press and the need to allow the press to publish freely on topics of public interest without harassment 9 Case 1:15-cv-07433-RWS Document 503 Filed 11/21/16…
…own, your Honor, doesn't seem to require a 3 nonparty witness to go through those burdensome and harassment 4 lengths. 5 THE COURT: But those statements have nothing to do 6 with this case. 7 MR. POTTINGER: Well, not…
…such an interrogatory is merely for the purpose of imposing a burden on Ms. Giuffre and her attorneys, not to mention the purposes of harassment. Pursuant to the Rules, if requested documents are not yielded in a “reasonable inquiry,” Ms…
…now in prison, enticed investors by falsely claiming that they could buy into lucrative pending settlements in whistleblower, sexual harassment and other cases. Edwards’ court papers say he knew nothing of Rothstein’s schemes, and federal authorities later determined Edwards…
…20 we're trying to do is make sure that this particular witness 21 who lives abroad is not subject to the continuing sense of 22 burden and harassment -- 23 THE COURT: I take it she has not been deposed. …
…the independence of the press and the need to allow the press to publish freely on topics of public interest without harassment and scrutiny by litigants seeking to conduct ‘fishing expeditions’ into [unpublished] materials in the hope that some relevant…
…the extent any right of privacy is applicable, the Court’s Protective Order affords Plaintiff all the privacy to which she is entited. Objection 11. There is no “harassment.” Federal Rule of Evidence 412, commonly referred to as the rape…
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