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 …
…01.27 re: legal advice 21. 2015.04.22 E-mail 7 pages Jeffrey Epstein Ghislaine Maxwell Common Interest Forwarding Common Interest Privilege …
…Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE005353, 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…
…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. …
… 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…
…Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE005353, 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…
…01.27 re: legal advice 21. 2015.04.22 E-mail 7 pages Jeffrey Epstein Ghislaine Maxwell Common Interest Forwarding Common Interest Privilege …
…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…
…Giuffre, no party’s search terms can yield an undue number of documents or an undue number of “false hits” for the other party to labor to review, since the search terms are crafted in a dynamic, “negotiated” fashion as…
…N.Y. 2004) (“Rule 45 requires that the party claiming a privilege prepare a privilege log.... Failure to submit a privilege log may be deemed a waiver of the underlying privilege claim.”)); Labatt Ltd. v. Molson Breweries, Nos. 93 CV…
…my office medical records, hospital medical records, patient information sheets, questionnaires, x-rays, other diagnostic studies and laboratory tests, emergency room records, out-patient records, consultation records, therapy records, and all other in-patient or out-patient hospital notes, charts…
…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…
…Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE005353, 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…
…Giuffre, no party’s search terms can yield an undue number of documents or an undue number of “false hits” for the other party to labor to review, since the search terms are crafted in a dynamic, “negotiated” fashion as…
…Ms. Giuffre has already produced documents Bates labelled GIUFFRE000001 to GIUFFRE005353, 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…
…01.27 re: legal advice 21. 2015.04.22 E-mail 7 pages Jeffrey Epstein Ghislaine Maxwell Common Interest Forwarding Common Interest Privilege …
…N.Y. 2004) (“Rule 45 requires that the party claiming a privilege prepare a privilege log.... Failure to submit a privilege log may be deemed a waiver of the underlying privilege claim.”)); Labatt Ltd. v. Molson Breweries, Nos. 93 CV…
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