…the Court to reconsider its unsealing order with respect to “13 of the 29 documents that this Court unsealed,” based on her assertion that the Court’s ruling was somehow inconsistent with its prior orders concerning other Non-Party Does…
…deliberately . According to Plaintiff, the Plaintiff made a deliberate decision to One can only assume then that contained the opposite: evidence unfavorable to Plaintiff and inconsistent …
…the objection (and non-objection) was lodged prior to receipt of the excerpts. Moreover, it is fundamentally inconsistent to permit “unsealing” but keeping their names anonymous. Ms. Maxwell raised some concerns about Doe 1 in the unredacted “Reply in Support…
…Generally, the work product privilege is waived when protected materials are disclosed in a manner which is either inconsistent with maintaining secrecy against opponents or substantially increases the opportunity for a potential adversary to obtain the protected information.” Id. at…
…on whether the names of two Does should be unsealed or unredacted in a particular set of documents. That is inconsistent with Paragraph 2(j). And it could take years before the Court could unseal even the First Five Motions. …
…she had . decided to tell I One can only assume then that Uiejoumal contained the opposite: evidence unfavorable to Plaintiff and inconsistent with the story she ultimately submitted to the Court in the CVRA case. I Presumably, the joumaf documented…
… For example, the September 25 Email is internally inconsistent in that it purports not to object to unsealing but in the same breath objects to the unsealing of the names of Does 1 and 2. This evinces a fundamental misunderstanding…
…Giuffre with Dershowitz’s name in it. 7 Case 1:15-cv-07433-LAP Document 1328-41 Filed 01/05/24 Page 13 of 31 innocence. But this inference is inconsistent with Ms. Giuffre’s description of the manuscript…
…to "prove" an assertion about the allegedly changing nature of a public "story." Similarly, to the extent that the Joinder Motion is inconsistent with published articles by Churcher, that would b e apparent from the face of the Articles themselves…
…Ms. Giuffre’s lawyers decided to treat her as a credible witness, and to accuse me of a heinous crime on the basis of her inconsistent and incoherent testimony alone. I was the only “academician” named as an abuser, despite…
…years after she had drafted a supposedly comprehensive account of it—are a recent fabrication. Just as a prosecutor would be bound to disclose such prior inconsistent statements by a complainant to the accused as impeachment material, United States v…
…needed to “prove” an assertion about the allegedly changing nature of a public “story.” Similarly, to the extent that the Joinder Motion is inconsistent with published articles by Churcher, that would be apparent from the face of the articles themselves…
…needed to “prove” an assertion about the allegedly changing nature of a public “story.” Similarly, to the extent that the Joinder Motion is inconsistent with published articles by Churcher, that would be apparent from the face of the articles themselves…
…Giuffre with Dershowitz’s name in it. 7 Case 1:15-cv-07433-LAP Document 1218-22 Filed 07/15/21 Page 13 of 31 innocence. But this inference is inconsistent with Ms. Giuffre’s description of the manuscript…
…request confidential treatment. If a non-party has a particular interest that is inconsistent with that of the parties they are free to request a separate protective order that addresses that concern. G. Proposed Paragraph 14 Should Be Subject to…
…statement to be admitted to rebut an “implied” charge of fabrication. The Second Circuit has made clear that the party admitting a prior consistent statement does “not have to point to a specific inconsistent statement” being attacked. United States v…
…needed to “prove” an assertion about the allegedly changing nature of a public “story.” Similarly, to the extent that the Joinder Motion is inconsistent with published articles by Churcher, that would be apparent from the face of the articles themselves…
…locate), nothing suggests it contains any relevant content. Perhaps Defendant is going to argue that Ms. Giuffre’s dreams are somehow inconsistent with her sworn testimony, but this would be pseudo-science that has no place before the jury. Cf…
…Generally, the work product privilege is waived when protected materials are disclosed in a manner which is either inconsistent with maintaining secrecy against opponents or substantially increases the opportunity for a potential adversary to obtain the protected information.” Id. at…
…the Court should compel Ms. Giuffre to disclose the name of the law enforcement agency with which she is cooperating, specifically (1) that the communications with law enforcement are “likely inconsistent” with Ms. Giuffre’s other statements; (2) that these…
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