…I have several. First, Florida statutes protect "[a]ny information in a videotaped statement of a minor who is alleged to be or who is a victim of sexual battery ... which reveals that minor' s identity." Fla. Stat.§ 119.071…
…on the subject matter in question. The second circumstance establishing a compelling need for the USVI to gain access through modification of the Protective Order is that even the identity of the deponent witnesses is not known or otherwise knowable…
…Law ................................................................ 7 B. All of the Information Sought by the Subpoena Is, At a Minimum, Protected by the Qualified Privilege Under the Shield Law ....................... 9 1. The Info…
…that Giuffre has already produced an unredacted copy of the manuscript to Dershowitz in this case. So if Dershowitz is correct about Doe’s identity, it is not at all clear what Doe is hoping to accomplish through continuing to…
…review of each document and to: (1) evaluate the weight of the presumption of public access to the materials; (2) identify and evaluate the weight of any countervailing interests; and (3) determine whether the countervailing interests rebut the presumption.” Jan…
…affirmed by the Second Circuit, found that Ms. Maxwell failed to identify deposition testimony that “constitute[] personal information which might lead to annoyance or embarrassment if unsealed” because, inter alia, she “refused to testify as to any consensual adult activity…
…at least one press source claimed to “crack” the redactions to identify witnesses and potential testimony by or 3 https://www.npr.org/2020/10/22/926590153/jeffrey-epstein-update-read-the-deposition-that- ghislaine-maxwell-fought-to-hide 4…
…DE 144 is a lawyer declaration referencing the exhibits in DE 144-1-7. The declarations accompanying the various Sealed Materials often identify a Non-Party. The Court may wish to simply redact all of the Non-Party names from…
… "Und er En g.lish Law, commun icati o ns between client and la wyer through an age nt will be protected by l egal advice privilege, but thi s will on ly app ly in sit uations wh ere…
…which is Giuffre v. Maxwell redux. It is plaintiff’s familiar litigation template: Identify a prominent person with any ties to Jeffrey Epstein, go to the media, make false allegations that that person participated in Mr. Epstein’s “sex trafficking…
…1 B. Ms. Maxwell’s Statement In Context Is Not Defamatory ................................... 3 II. MS. MAXWELL’S STATEMENTS ARE PROTECTED BY PRIVILEGE .......... 6 A. Qualified Privilege May Form the Basis for a Rule 12(b)(6) Dismissal ............. 6 B. Ms. Maxwell…
…communication. 13. Identify the basis, including all underlying facts, for your contention that Plaintiff’s claims are barred because the statements made by Ms. Maxwell or her agent were protected by the self-defense privilege. ANSWER: Ms. Maxwell objects to…
…the subpoena served on Ms. Ransome seeks documents that are wholly irrelevant to the underlying action including protected financial information and documents or communications between Sarah Ransome and her attorneys, which are protected by the attorney- client privilege and the…
…the subpoena served on Ms. Ransome seeks documents that are wholly irrelevant to the underlying action including protected financial information and documents or communications between Sarah Ransome and her attorneys, which are protected by the attorney- client privilege and the…
…names and 16 substituting initials and things like that. They don't 17 identify the names of victims of sexual assaults. 18 But the law is such that we have to decide what 19 standard applies. But in any event…
…the subpoena served on Ms. Ransome seeks documents that are wholly irrelevant to the underlying action including protected financial information and documents or communications between Sarah Ransome and her attorneys, which are protected by the attorney- client privilege and the…
…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…
…presumption of access to these documents, the Court should also find that Ms. Maxwell and J. Doe have failed to identify any non-generalized, non-speculative interest that would outweigh these First Amendment and common law rights of access. Therefore…
…under Brown’s footnote 5. Throughout its brief the Miami Herald argues we failed to identify a compelling or other countervailing interest that would outweigh a presumption of access or we failed to carry our burden of establishing such an…
…1:15-cv-07433-LAP Document 66 Filed 03/23/16 Page 13 of 35 13 G3hdgium 1 THE COURT: You get it. 2 MS. MENNINGER: It is copyright and proprietary 3 protected. We're not going to produce it…
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