…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…
…s Objection Should Be Overruled. ........................................................ 12 A. Doe 183’s Arguments Regarding Judicial Documents............................. 12 B. Doe 183’s Purported Countervailing Interests ......................................... 15 …
…non-party, as opposed to by motion.1 It would also delay the unsealing process for the motions and related docket entries to which the public has a greater interest in seeing published. In the interest of minimizing disputes, Plaintiff…
…as she poses to promote body positivity …
…information protected by the attorney/client privilege, the work-product doctrine, Rule 408 of the Federal Rules of Evidence, any common interest privilege, joint defense agreement or any other applicable privilege. 4. Ms. Maxwell objects to the Interrogatories to the…
…party witnesses. Release of such confidential information outside of the litigation could expose the parties to ‘annoyance, embarrassment, [and] oppression and result in significant injury to one or more of the parties’ business or privacy interests.” - Defendant, Ghislaine Maxwell, March…
… I don't have the 3 date in front of me. I'm sorry. 4 THE COURT: That solves that problem. I have the 5 joint interest agreement. It's been submitted. It occurs to 6 me that it is…
…§1332 (diversity jurisdiction) as Giuffre and Maxwell are citizens of different states and the amount in controversy exceeds seventy-five thousand ($75,000), exclusive of interest and costs. 4. This Court has personal jurisdiction over Maxwell. Maxwell resides in New…
…pending motion to join this action. The Court should deny the motion. Dershowitz has not established any direct interest in this Crime Victims’ Rights Act (CVRA) action that would entitle him to intervene as of right under Fed. R. Civ…
…2d Cir. 2019). We respectfully write to ask this Court to protect those non-party interests; a request that is consistent with long-standing Circuit precedent establishing that this responsibility “rests heavily upon the shoulders” of the district court. In…
…§1332 (diversity jurisdiction) as Giuffre and Maxwell are citizens of different states and the amount in controversy exceeds seventy-five thousand ($75,000), exclusive of interest and costs. 4. This Court has personal jurisdiction over Maxwell. Maxwell resides in New…
…§1332 (diversity jurisdiction) as Giuffre and Maxwell are citizens of different states and the amount in controversy exceeds seventy-five thousand ($75,000), exclusive of interest and costs. 4. This Court has personal jurisdiction over Maxwell. Maxwell resides in New…
… that for that important public interest to be overridden by a claim of privilege the purpose of submission to the party's legal advisers in anticipation of litigation must be at least the Case 1:15-cv-07433-RWS Document…
…and Cassell continue to represent [Dershowitz accuser] Virginia Giuffre in separate pending matters, and shall continue to advance her legitimate legal interests in those matters. As expressly understood by the parties upon the execution of the Confidential Settlement Agreement and…
…19 know, to put up a listing. And then she asked me if 20 I knew anyone that would be interested in working 21 for her. 22 Q. Did she describe what that work was going 23 to be? 24…
…1:15-cv-07433-LAP Document 1285 Filed 12/05/22 Page 2 of 6 information necessary to evaluate her privacy interests at stake.) See also Appendix (Summary Chart).1 While Doe 171 strenuously maintains her right to remain anonymous…
…19 know, to put up a listing. And then she asked me if 20 I knew anyone that would be interested in working 21 for her. 22 Q. Did she describe what that work was going 23 to be? 24…
…15-cv-07433-LAP Document 1286 1285 Filed 12/05/22 Page 2 of 6 information necessary to evaluate her privacy interests at stake.) See also Appendix (Summary Chart).1 While Doe 171 strenuously maintains her right to remain anonymous…
…the public in order to advance and carry out his crimes and torts. At all relevant times, Defendant Epstein owned and continues to own, directly or through nominee individuals used to conceal his interests, a fleet of airplanes, motor vehicles…
…19 know, to put up a listing. And then she asked me if 20 I knew anyone that would be interested in working 21 for her. 22 Q. Did she describe what that work was going 23 to be? 24…
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