…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) ………………………………………
…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…
…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…
…4 So we are awaiting a ruling. We believe those 5 individuals should be protected under the Court's protective 6 order and those names kept confidential during the course of 7 this, and it is my understanding that defendants…
…III. The Applicable Standard Pursuant to Federal Rule of Civil Procedure 4 5 ( c) ( 3) (A), a court "must quash or modify a subpoena that (iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies…
…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. …
…For other providers, no records were produced. Where no documents were produced, Plaintiff failed to identify the dates and nature of the treatment received, as requested in the Interrogatory. Id. Plaintiff failed therein to identify any treatment providers prior to…
…each category of damages claimed by the disclosing party—who must also make available for inspection and copying as under Rule 34 the documents or other evidentiary material, unless privileged or protected from disclosure, on which each computation is based…
…For other providers, no records were produced. Where no documents were produced, Plaintiff failed to identify the dates and nature of the treatment received, as requested in the Interrogatory. Id. Plaintiff failed therein to identify any treatment providers prior 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…
…354 Filed 08/10/16 Page 5 of 40 that Ms. Maxwell has published “numerous” false statements, yet Plaintiff stubbornly refuses to identify each of these allegedly false statements. Interrogatory No. 6 asked simply that for each allegedly false statement…
…For other providers, no records were produced. Where no documents were produced, Plaintiff failed to identify the dates and nature of the treatment received, as requested in the Interrogatory. Id. Plaintiff failed therein to identify any treatment providers prior to…
…every rule applicable to motions to compel: her counsel did not confer; the motion fails to identify any discovery request it is seeking to “compel” a response to; and it failed to list verbatim any such allegedly unanswered discovery request…
…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 .............................................…
…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…
…opinion, the Second Circuit suggested in dicta that “[t]he District Court may also order the parties to identify and notify additional parties whose privacy interests would likely be 1 Based on lessons learned from past rounds of unsealing, the…
…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…
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