…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 .........................................................................................................…
…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…
…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…
…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…
…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…
…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: …
…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…
…380 F.3d 110 (2d Cir. 2004) (per curiam) (witnesses and third parties "possess strong privacy interests, because being identified as part of a law enforcement investigation could subject them to 'embarrassme nts and harassment'" ), "with the deviant and the…
…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…
…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…
…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…
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