gov.uscourts.nysd.447706.1219.10.pdf PDF
…01.27 re: legal advice 21. 2015.04.22 E-mail 7 pages Jeffrey Epstein Ghislaine Maxwell Common Interest Forwarding Common Interest Privilege …
…01.27 re: legal advice 21. 2015.04.22 E-mail 7 pages Jeffrey Epstein Ghislaine Maxwell Common Interest Forwarding Common Interest Privilege …
…01.27 re: legal advice 21. 2015.04.22 E-mail 7 pages Jeffrey Epstein Ghislaine Maxwell Common Interest Forwarding Common Interest Privilege …
…01.27 re: legal advice 21. 2015.04.22 E-mail 7 pages Jeffrey Epstein Ghislaine Maxwell Common Interest Forwarding Common Interest Privilege …
…of New York v. Meridien Biao Bank Tanzania, Ltd., 171 F.R.D. 135 (S.D.N.Y. 1997).................................................................................................6 Barrett v. Forest Labs., Inc., No. 12-CV-5224 (RA), 2015 WL 4111827 (S.D.N.Y. July 8, 2015) …
…Since the term ‘public interest’ is flexible, a judicial determination must be made on the specific facts of each case to determine if sufficient potential harm to the public interest exists to render the privilege operable.” Labarbera v. Ulster Cty…
…01.27 re: legal advice 21. 2015.04.22 E-mail 7 pages Jeffrey Epstein Ghislaine Maxwell Common Interest Forwarding Common Interest Privilege …
…to their parents. Their clothing was confiscated and placed into property by the responding officers, to be sent to the lab for testing. See property receipts. This investigator then conducted an interview with Fire/Rescue Officer Ellen F. Delai who…
…2016 Confidentiality Order regarding Virginia Giuffre’s deposition, attached hereto as Exhibit 17. 18. Documents produced and bates labelled Non-Party VR 000001 – Non-Party VR 000644, in the Bradley Edwards and Paul Cassell v. Alan Dershowitz matter, 14 …
…purpose of harassing and intimidating this victim. Subject to the forgoing objections Ms. Giuffre produces herewith non- privileged documents bates labelled GIUFFRE000001 to GIUFFRE003190 and will continue to supplement this production. Ms. Giuffre is withholding documents based on her objections…
…1999)....................................................................................................................18 iii Case 1:15-cv-07433-LAP Document 1320-18 Filed 01/03/24 Page 5 of 40 Falco v. N. Shore Labs. Corp., 866 So.2d 125…
…11 we don't have to worry about the individuals who have not 12 objected. Is there a mechanism by which we can address that so 13 we won't have to labor through those in each section? 14 THE…
…Ms. Giuffre has already produced her responsive communications, which are found in documents Bates labelled GIUFFRE000001 to GIUFFRE007566. 6. Identify any “false statements” attributed to Ghislaine Maxwell which were “published globally, including within the Southern District of New York” as…
…he has found himself unable to stem the tide of media reports and public statements by Ms. Giuffre and her lawyers labeling him a pedophile and sexual abuser. Professor Dershowitz seeks to intervene here to assert his First Amendment and …
…Person Subject to a Subpoena; Enforcement. must organize and label them to correspond to the categories in the demand. (B) Form for Producing Electronically Stored Information Not Specified (1) A voiding Undue Burden or Expense…
…1hcy nrc kq11 ill lhc ordin:,ry coun,c ol bt1;incs~ or (di Protecting a l'ct'SQn Subject to a Subpoena; Enl"orccmcnt. must 11rganizc and label them to cnt~·csponcl to the catej!one, fr, the demand. …
…the subject of extensive publicity, much of it salacious. A Google search for “Jeffrey Epstein” returns 508,000 entries, the most recent of which center on the new nominee for Secretary of Labor, Alexander Acosta, who, when he was United…
… Sanctions. A party oc attorney mllSt organiu and label them to correspond to the categories in the demand. responsible for issuing and serving a subpoena must take reasonable steps (B) Form/or Producing Electronically Stor,d lnfor,no1io,, Not Specified…
…01.27 re: legal advice 21. 2015.04.22 E-mail 7 pages Jeffrey Epstein Ghislaine Maxwell Common Interest Forwarding Common Interest Privilege …
…2006); In re Application for Subpoena to Kroll, 224 F.R.D. 326, 328 (E.D.N.Y. 2004); Labatt Ltd. v. Molson Breweries, Nos. 93 CV 75004, 94 CV 71540(RPP), 1995 WL 23603 (S.D.N.Y. Jan…
…Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE003190, and will produce non-privileged documents responsive to this Request limited to documents that do not depict images of her minor children as described supra and will continue to…
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