gov.uscourts.nysd.447706.46.0.pdf PDF
… 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) ………………………………………
… 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) ………………………………………
…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. …
…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…
…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…
…the motion briefly proffered the circumstances that would qualify the two women as “victims” eligible to assert rights under the CVRA. See 18 U.S.C. 3771(e) (defining “crime victim” protected under the Act). With regard to Ms. Giuffre…
…the motion briefly proffered the circumstances that would qualify the two women as “victims” eligible to assert rights under the CVRA. See 18 U.S.C. 3771(e) (defining “crime victim” protected under the Act). With regard to Ms. Giuffre…
…APPEAR AND RESPOND . 10 IV. MS. RANSOME MUST BE REQUIRED TO PRODUCE REPONSIVE DOCUMENTS THAT HAVE BEEN WITHELD WITHOUT BASIS, AND IDENTIFY ANY OTHER DOCUMENTS WITHELD ................................................................................................... 12 CONCLUSION .............................................…
…10 IV. MS. RANSOME MUST BE REQUIRED TO PRODUCE REPONSIVE DOCUMENTS THAT HAVE BEEN WITHELD WITHOUT BASIS, AND IDENTIFY ANY OTHER DOCUMENTS WITHELD ................................................................................................... 12 CONCLUSION ..................................................................…
…irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Maxwell further objects to this Request to the extent it seeks documents or information protected by the attorney/client privilege, the work-product doctrine…
…information itself (ii) These acts may be reqtJired only as directed in the order, and the privileged or protected, will enable the parties to asses.~ the claim. order must protect a person who is neither a party nor a…
…Giuffre’s relationships with her lawyers that Ms. Giuffre’s counsel contends are protected by the attorney-client and work product privileges; Documents relating to prescriptions and medical records that are unrelated to defamation and the sexual abuse she…
…2d 260, 263 (S.D.N.Y. 2013) (“the Court notes that Plaintiffs’ letter is a sur-reply filed without permission of the Court and does not identify new controlling law, and therefore will not be considered.”). To the extent…
…Ill. May 14, 2008) (“the court finds that the request to identify ‘all documents that refer or relate to each such person's contribution’ to be overbroad and unduly burdensome, and sustains the objection to that part of the interrogatory”)…
…290 F.R.D. 421, 434 (S.D.N.Y. 2013) (“communications are protected where there is a disclosure by A to the attorney representing B and vice-versa”). Therefore, Maxwell’s 4 communications with other parties, outside the presence…
…manner that, without revealing information itself privileged or protected, will enable other parties to assess the claim.” (emphasis supplied). The Local Rules are even more specific, and require a party withholding a document to identify “(i) the type of document…
…10th Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Email: [email protected] Defendant in this action. CONFIDENTIAL as to victims' identity …
…Therefore, Ms. Giuffre is now required to take the deposition of pilot Dave Rodgers to authenticate his pilot logs and the identity of the individuals on various flights. In addition, as the Court knows, this case involves allegations that Ms…
…commenting on, regarding, discussing, showing, describing, reflecting, analyzing or constituting. 9. "Identify" means, with respect to any ''person," or any reference to tbe '' identjty" of any '·person," to provide the name, home address, telephone number, business name, business address, business…
…Therefore, Ms. Giuffre is now required to take the deposition of pilot Dave Rodgers to authenticate his pilot logs and the identity of the individuals on various flights. In addition, as the Court knows, this case involves allegations that Ms…