gov.uscourts.nysd.447706.140.3.pdf PDF
…Document 140-3 Filed 05/04/16 Page 1 of 4 EXHIBIT 3 Case 1:15-cv-07433-LAP Document 140-3 Filed 05/04/16 Page 2 of 4 § 42:178.Public-interest privilege, 7 Carmody-Wait 2d …
…Document 140-3 Filed 05/04/16 Page 1 of 4 EXHIBIT 3 Case 1:15-cv-07433-LAP Document 140-3 Filed 05/04/16 Page 2 of 4 § 42:178.Public-interest privilege, 7 Carmody-Wait 2d …
…140-2 Filed 05/04/16 Page 1 of 3 EXHIBIT 2 Case 1:15-cv-07433-LAP Document 140-2 Filed 05/04/16 Page 2 of 3 § 23:38.”Public interest” privilege, 1 Modern New York Discovery …
…Edwards and Cassell re attorney defense/commo 1 2/12/2015 6:14 Virginia Giuffre [email protected] impressions and legal advice relating to deposition testimony n interest Withheld 3 msg …
…Motion to Compel are at once novel (Plaintiff asserts, for example, a “public interest privilege” which is unavailable to individual, non-governmental litigants) and mundane (Plaintiff completely refused to answer interrogatories, even though they comply with the Federal and Local…
…5 due to.. VR ..lack of credibility " The new interest in this old settled case results from lawyers representing some of JE victims filed a suit against the US government not JE . They contend that the Us govt violated their…
…Edwards and Cassell re attorney defense/commo 1 2/12/2015 6:14 Virginia Giuffre [email protected] impressions and legal advice relating to deposition testimony n interest Withheld 3 msg …
…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…
…Edwards and Cassell re attorney defense/commo 1 2/12/2015 6:14 Virginia Giuffre [email protected] impressions and legal advice relating to deposition testimony n interest Withheld 3 msg …
…Maxwell’s motion is denied. I. Legal Standard “A motion for reconsideration is an extraordinary remedy to be employed sparingly in the interests of finality and conservation of scarce judicial resources.” Drapkin v. Mafco 1 (Letter from Laura Menninger (“Mot.”)…
…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…
…Edwards and Cassell re attorney defense/commo 1 2/12/2015 6:14 Virginia Giuffre [email protected] impressions and legal advice relating to deposition testimony n interest Withheld 3 msg …
…the Maxwell records was to give the Jeffrey Epstein network the attention it deserved. Mr. Cernovich had informed many members of the press that Epstein had escaped justice, with little to no interest from them. Other than a May 4…
…from Sarah Kellen and Nadia Marcinkova for Purposes of Obtaining an Adverse Inference (DE 698). In the interest of brevity before the Court, Ms. Giuffre adopts all of the facts and arguments from the aforementioned motion and incorporates them herein…
…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…
…May 3rd, please provide the following documents on or before April 27th, 2016. All documents withheld on the basis of the “public interest privilege,” other than Plaintiff’s actual statements to any law enforcement agency, which are to be…
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