…that Jane Doe No. 3 suffered as a minor child, and Defendant’s threats and intimidation, it would be both unreasonable and oppressive to require this non-party to comply with this subpoena duces tecum. Accordingly, Defendant’s subpoena should…
…re 11 seeking information to be able 12 to -- the witness has already 13 expressed fear about her -- 14 people currently going after her. 15 So we would object to that 16 intimidation of a nonparty 17 witness. 18 Q…
…bullying, harassing, and intimidation. This Court has already held that summary judgment based upon an asserted privilege protecting defamatory pre-litigation communications is precluded when a plaintiff raises “a genuine issue as to malice and appropriate purpose.” Block, 691 F…
…re 11 seeking information to be able 12 to -- the witness has already 13 expressed fear about her -- 14 people currently going after her. 15 So we would object to that 16 intimidation of a nonparty 17 witness. 18 Q…
…pursuant to Local Civil Rule 26.2(c). Ms. Giuffre objects to the requests in that they seek to invade her privacy for the sole purpose of harassing and intimidating Ms. Giuffre who was a minor victim of sexual trafficking. …
…to Giuffre, they were not made in good faith anticipation of litigation, and instead were made for the inappropr iate purpose of "bul ly(ing] ," "harass]ment]," and "intimid[ation]." See Front, 28 N.E.3d at 19 (2015). According…
…Defendant’s intimation that there is an undisclosed account is directly beneath a heading that states: “There is no ‘Undisclosed’ Account.” 4 Case 1:15-cv-07433-LAP Document 1219-43 Filed 07/15/21 Page 5 of 12…