…that it seeks information protected by the attorney client and work product privileges. Ms. Giuffre objects to this interrogatory in that it is not limited in time or to the subject nature of this litigation. 8. Identify the individuals referenced…
…that it seeks information protected by the attorney client and work product privileges. Ms. Giuffre objects to this interrogatory in that it is not limited in time or to the subject nature of this litigation. 8. Identify the individuals referenced…
…protected by the attorney-client privilege, the attorney work product privilege, joint defense/common interest privilege, the public interest privilege, and any other applicable privilege. Ms. Giuffre objects in that this request is overly broad and unduly burdensome. 6. Identify…
…protected by the attorney-client privilege, the attorney work product privilege, joint defense/common interest privilege, the public interest privilege, and any other applicable privilege. Ms. Giuffre objects in that this request is overly broad and unduly burdensome. 6. Identify…
…that it seeks information protected by the attorney client and work product privileges. Ms. Giuffre objects to this interrogatory in that it is not limited in time or to the subject nature of this litigation. 8. Identify the individuals referenced…
…that it seeks information protected by the attorney client and work product privileges. Ms. Giuffre objects to this interrogatory in that it is not limited in time or to the subject nature of this litigation. 8. Identify the individuals referenced…
…1331. 2. Plaintiff files this Complaint under a pseudonym in order to protect her identity because this Complaint makes allegations of a sensitive sexual nature and disclosure of Plaintiffs name publicly will cause firther harm to her. 3. At all…
…minimal redactions for personally identifiable information, the names of nonparties as well as the families of nonparties’ that could be used to identify the nonparties, and descriptions of nonparty conduct that would allow readers to discern the identity of a…
…1115), we determined that in compiling the declaration, Plaintiff’s counsel used the incorrect Non-Party pseudonyms to identify certain Non-Parties because counsel was relying on a prior, outdated version of the Non- Party list. 5. I therefore submit…
…the updated Order and Protocol for Unsealing Decided Motions, ECF No. 1108, I used best efforts to identify the most current addresses for J. Doe 92 through J. Doe 185. 5. I mailed the following documents to the Non-Parties…
…28, 2019, asking the parties to identify the docket entries they argue should not be unsealed and the reasons supporting their arguments. As a party seeking unsealing of these very documents, Intervenors unquestionably have a right to meaningfully respond. They…
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