…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 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…
…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…
…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…
…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 ..................................................................…
…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…
…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…
… . : 1-05-000368 (Continued) the previous houseman left . Rodriguez stated that it was his responsibility to keep the identity of the masseuses private. Mr. Epstein had a massage in the morning and one in the afternoon. Mr. Rodriguez stated he…
… . : 1-05-000368 (Continued) the previous houseman left . Rodriguez stated that it was his responsibility to keep the identity of the masseuses private. Mr. Epstein had a massage in the morning and one in the afternoon. Mr. Rodriguez stated he…
…1 I. PLAINTIFF’S PRODUCTION OF KEY DOCUMENTS AFTER HER DEPOSITION NECESSITATES ADDITIONAL EXAMINATION ............................................................. 3 A. Plaintiff failed to identify her health care providers and produce their records prior to her deposition, despite this Court’s or…
…4 Case 1:15-cv-07433-RWS Document 17-1 Filed 12/01/15 Page 5 of 13 8. “Identify” means, with respect to any “person,” or any reference to the “identity” of any “person,” to provide the name…
…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…
… . : 1-05-000368 (Continued) the previous houseman left . Rodriguez stated that it was his responsibility to keep the identity of the masseuses private. Mr. Epstein had a massage in the morning and one in the afternoon. Mr. Rodriguez stated he…
…commenting on, regarding, discussing, showing, describing, reflecting, analyzing or constituting. 9. “Identify” means, with respect to any “person,” or any reference to the “identity” of any “person,” to provide the name, home address, telephone number, business name, business address, business…
…15 Civ. 7433 (LAP) Dear Judge Preska: Paragraph 1 of the Court’s October 28 Order (Doc.998) required the parties to identify motions decided by the Court and related papers that were sealed or redacted (“Sealed Materials”). Paragraphs 3…
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