…weight of presumption of public access that should be afforded to an item, (b) the identification and weight of any countervailing interests supporting continued sealing/redaction of the item, and (c) whether the countervailing interests rebut the presumption of public…
…Gow Ghislaine Maxwell Brian Attorney Agent / Communication re: Attorney-Client Basham Client legal advice 2015.01.06 E-Mail Ghislaine Maxwell Jeffrey Epstein Common Inte…
…protected by the attorney/client privilege, the work-product doctrine, the common interest privilege or any other applicable privilege. Subject to and without waiving the above objections, Maxwell is withholding documents outside of the Relevant Periods described in paragraph15, supra…
…12 B. There Is No Risk of Undue Delay or Prejudice .........................................12 C. Professor Dershowitz Has a Compelling Interest in Access That Is Not Represented by Any Existing Party ........................................1…
…Gow Ghislaine Maxwell Brian Attorney Agent / Communication re: Attorney-Client Basham Client legal advice 2015.01.06 E-Mail Ghislaine Maxwell Jeffrey Epstein Common Inte…
…Work Product/joint 2/16/2015 [email protected],robiej defense/common 2 1:05 [email protected] [email protected] Discussion of evidence among client and attorneys interest Wit…
…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…
…Gow Ghislaine Maxwell Brian Attorney Agent / Communication re: Attorney-Client Basham Client legal advice 2015.01.06 E-Mail Ghislaine Maxwell Jeffrey Epstein Common Inte…
…28/2015 Email with Giuffre, McCawley, Edwards and defense/common 19 17:47 Virginia Giuffre [email protected] Henderson re discussion of draft statement interest Withheld 3 msg …
…with Giuffre, Edwards, Pottinger and interest/work 30 18:40 Stan [email protected] McCawley re legal advice related to VRS product Withheld 1 msg …
…93, and 151. The parties to this action and other interested parties are invited to appear telephonically for the Court’s rulings as to these objections on Tuesday April 19, 2022, at 10:30 a.m., using the following information…
…Parties. First, Doe criticizes the Original Parties’ compliance with the Court’s unsealing orders and directives to redact the names of non-parties whose interests the Court has not yet considered, which has involved an immense amount of resources. ECF…
…171, and 183. The parties to this action and other interested parties are invited to appear telephonically for the Court’s rulings as to these objections on Friday November 18, 2022, at 11 a.m., using the following information: dial…
…So to prove plaintiff is a liar, Mr. Dershowitz is interested in unearthing all of the many false and salacious allegations plaintiff ever has made. The Miami Herald has its own economic interests. What media would decline to seize any…
…15-cv-07433-LAP Document 1196 Filed 01/27/21 Page 3 of 32 3 1 materials; (2) identify and evaluate the weight of any 2 countervailing interests; and (3) determine whether the 3 countervailing interests rebut the presumption. 4 …
…Intervenors Miami Herald Media Company, 6 Julie K. Brown (15 Civ. 7433) BY: CYNTHIA GIERHART, ESQ. 7 KRIEGER, KIM & LEWIN LLP 8 Attorneys for Interested Party John Doe (15 Civ. 7433) BY: NICHOLAS J. LEWIN, ESQ. 9 PAUL M. KRIEGER…
…public interest privilege, and any other applicable privilege. 1 Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 3 of 45 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) Ms…
…Agent / Communication Attorney-Client
1028 Basham Client re: legal advice
6. 2015.01.06 E-Mail 1029 Ghislaine Maxwell Jeffrey Epstein Common
…Risk of Undue Delay or Prejudice .........................................12 C. Professor Dershowitz Has a Compelling Interest in Access That Is Not Represented by Any Existing Party ........................................13 II. THE FIRST AMENDMENT AND TH…
… Attached hereto as Exhibit 16 is a true and correct copy of Common interest agreement. I declare under penalty of perjury that the foregoing is true and correct. /s/ Sigrid McCawley Sigrid McCawley Case 1:15-cv-07433-LAP…
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