…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…
… 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 …
…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…
…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 …
…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…
…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…
…asserts, without factual or legal support, that her financial information is being sought “for the purpose of harassment and intimidation.” Because Ms. Ransome failed to address the relevance argument asserted by the Motion, this issue should be deemed admitted. Compare…
…arbiter in the room. Thus, for efficiency purposes and to protect Ms. Maxwell from harassment and oppression, we request that the Court appoint a Special Master to preside over Ms. Maxwell’s third deposition and be given the following powers: …
…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…
…of privacy. A non-party should not be subjected to undue harassment serving no admissible purpose. 9 Case 1:15-cv-07433-LAP Document 1332-8 Filed 01/08/24 Page 11 of 27 Without waiving such objections, a…
…asserts, without factual or legal support, that her financial information is being sought “for the purpose of harassment and intimidation.” Because Ms. Ransome failed to address the relevance argument asserted by the Motion, this issue should be deemed admitted. Compare…
…R.D. 391 (E.D.Cal.2009) (evidence of employer's current financial worth was relevant to issue of punitive damages, and thus was discoverable in Title VII action alleging sexual harassment and retaliation, where complaint sought punitive damages, deposition…
…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. Giuffre is not obligated to expend all of her time and resources on a…
…R.D. 391 (E.D.Cal.2009) (evidence of employer's current financial worth was relevant to issue of punitive damages, and thus was discoverable in Title VII action alleging sexual harassment and retaliation, where complaint sought punitive damages, deposition…
…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…
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