…Court or any Orders of the Court. 3. Ms. Maxwell objects to the Requests to the extent they seek documents or information protected by the attorney/client privilege, the work-product doctrine, Rule 408 of the Federal Rules of Evidence…
…under Rule 26.3(c)(7), Southern District of New York Local Civil Rules. 8. “Identify” (with respect to persons) incorporates the definition as set forth in Rule 26.3(c)(3), Southern District of New York Local Rules. Therefore…
…of “any and all documents” filed in Giuffre v. Maxwell that “identify the men who abused the girls trafficked by Jeffrey Epstein and Defendant Maxwell.” Appellant’s App’x at 260. The District Court denied TGP’s motion to intervene…
…they claim that Plaintiff has not shown that unsealing serves the public interest. Does 55 & 56 Reply Objs. 2-3. It is the Does’ burden to identify concrete, countervailing interests that outweigh the presumption of public access. See Lytle v…
…Giuffre of any practical ability to use the discovery, and, importantly, it was incumbent on Defendant to identify this account. The Second Circuit has stated, “[w]here documents, witnesses, or information of any kind relevant issues in litigation is or…