…TABLE OF CONTENTS INTRODUCTION .......................................................................................................................... 1 ARGUMENT .................................................................................................................................. 2 I. CHURCHER IS A MATERIAL FACT WITNESS …
…Court suspending the First Amendment right of access). Mr. Cernovich’s journalistic focus is on Maxwell and in reporting on Jeffrey Epstein’s accusations.2 In fact, in the 2016 presidential election, Epstein’s activities were the focus of political…
…Reporter and Source .................................................................................... 3 B. The Record Does Not Support Maxwell’s Contention that Churcher Is a “Fact Witness,” and Not a Journalist ....................................................... 6 …
…Specifically, I seek to unseal portions of a brief (the “Reply Brief”) and certain emails (the “Emails”) that were submitted in connection with a motion to quash a testimonial subpoena directed to British tabloid journalist Sharon Churcher, and a draft…
…generally id., Ex.K. He did disclose his intent and strategy underlying his preparation of the statement he caused to be transmitted January 2, 2015, via press agent Ross 1111 Gow to various journalists. See id., Ex.K ¶¶ 12-24…
… If it helps, have your attorney write a suggested column- oriented item re your case and if it's written in 'journalistic style,' Colin and I can pop it off to Emily, as a possible piece f, her renowned Page…
…correspondent, columnist, writer, commentator, investigative journalist, 9 Case 1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 11 of 40 photojournalist, newspaper person, freelance reporter, stringer, or any other employee of any media organization or…
…Sharon Churcher, Plaintiff’s friend, advocate and former journalist with the Daily Mail, who filed a Motion to Quash her subpoena on the day before her scheduled deposition,2 and (2) Plaintiff, who refused to answer questions at her deposition…
…have had with any author, reporter, correspondent, columnist, writer, commentator, investigative journalist, photojournalist, newspaper person, freelance reporter, stringer, or any other employee of any media organization or independent consultant to the same, including: a. the date of any such Communication…
…told her he was retired from the British military and was currently working on a book. Janet Marshall described herself as a journalist.' Last summer, DailyMail.com previously tracked down Maxwell in Manchester-by-the-Sea, living at a home…
…1979))). Mr. Dershowitz filed an appeal (Doc.504), which is pending. In January 2017 a purported journalist Michael Cernovich requested unsealing of Ms. Maxwell’s summary judgment brief, her attorney’s declaration in support of the summary judgment motion, and…
…Sharon Churcher, Plaintiff’s friend, advocate and former journalist with the Daily Mail, who filed a Motion to Quash her subpoena on the day before her scheduled deposition,2 and (2) Plaintiff, who refused to answer questions at her deposition…
…Attorneys have had with any author, reporter, correspondent, columnist, writer, commentator, investigative journalist, photojournalist, newspaper person, freelance reporter, stringer, or any other employee of any media organization or independent consultant to the same, including: a. the date of any such…
…the accusations against him. On January 19, 2017, Cernovich, an independent blogger and self‐described “popular political journalist,”7 moved to intervene, seeking to unseal the summary judgment record, and Dershowitz joined his motion. On April 6, 2018, after the…
…semblance of a justification for the Court to maintain the secrecy of a manuscript she has already shared with publishers and journalists and whose contents she has selectively disclosed already in numerous media appearances over the course of several years…
…e- mails, text messages, instant messages, videotapes, photographs, notes, letters, memoranda, forms, books, magazines, resumes, notebooks, ledgers, journals, diaries, calendars, appointment books, papers, agreements, contracts, invoices, analyses, transcripts, plaques, correspondence, telegrams, drafts, data processing or computer di…
…your Honor, is that this witness claims 23 that she came forward after communicating with a journalist. 24 She said she e-mailed that journalist several times. She 25 testified to the e-mails with the journalist about the subject…
…26/18 08/27/18 Page Page 64 of of 43 41 Sweet, D.J. Third-party proposed intervenors The Miami Hera…
…not as a journalist. Page 3 of 69 GIUT-T RE003700 CONFIDENTIAL Case 1:15-cv-07433-LAP Document 1325-2 Filed 01/04/24 Page 5 of 70 I am sure you understand that it has been a…
…No. 8 Has Been Deemed Improper Under Local Rule 33.3............................................................................13 b. Ms. Giuffre Has Not Located Any “Diaries Or Journals,” And She Has Produced Travel Logs And Passports ............…
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