…any identifying information, for example, their Social Security 21 number or an address be able to be protected for those that are 22 coming to testify. I know that makes it a little bit more 23 difficult, but if we…
… Defendant’s Communication with Attorneys Philip Barden, Mark Cohen, and Brett Jaffe Are Protected by the Attorney-Client Communication Privilege (Entries 1, 2, 9 and 17) ………………………………………
…pursuant to the Court’s Order [DE 134] dated May 2, 2016.1 ARGUMENT Statements made by witnesses to law enforcement are protected by the public interest privilege, which “exists to encourage witnesses to come forward and provide information in…
…publicly disclosed volumes of information related to her allegations, to claim that letters or emails from her lawyers or other documents sent to any law enforcement agency are protected by any privilege. Plaintiff lacks standing to raise the issue and …
…those events is protected from disclosure by law. 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.”…
…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…
…This Court’s Order ............................................................................................23 5. Information About Ms. Giuffre’s Sexual Abuse is Protected by Florida Statutes ..................................................…
…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…
…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…
…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 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…
…Statutes Plaintiff also cites Colorado statutes which, she claims, support the proposition that her identity as the victim of domestic violence is protected by Colorado law. It is not. Section 13- 90-107(k),3 is a testimonial privilege statute…
…serving party tangible things in a manner that, without revealing information itself may move the court for the district where compliance is required for an privileged or protected, will enable the parties to assess the claim. order compelling production or…
…due to holding both French and British passports, she has the ability to 'live beyond the reach of extradition indefinitely'. Prosecutor Moe argued: 'She is good at living under an assumed identity. There really can be no question that she…
…federal court proceedings. As a result, that filing is indisputably protected by Florida's broad and absolute litigation privilege. Consequently, plaintiffs' motion for summary judgment as it relates to the pending counterclaim against them should also be granted. ARGUMENT II. …
…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…
…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…
…information itself (ii) These acts may be required only as directed in the order, and the privileged or protected, will enable the parties to assess the claim. order must protect a person who is neither a party nor a party…
…These aul, may be reqllired only as directed in the order, und lhe privileged or protected, will enable the parties to assess ille claim. order mllst protect a person who is neither II pHny nor a party'~ "metr tiol!…
…Professional” or “Health Care Institution” in Colorado Revised Statute § 13-64-202(3) and (4). 9. “Identify” means to specify as to a “Person,” the name, address, telephone number and any other identifying information possessed by You or Your Attorneys…
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