…witness should be entitled to rely upon the enforceability of a protective order against any third parties.’” In this case, the parties and multiple other deponents have relied on this Court’s Protective Order in giving testimony and producing documents . …
…negations: MS. MCCAWLEY: Your Honor, if the intent here is to continue to spew the confidential settlement negotiations and have Dershowitz go to New York or other locations to say these things again, I would object to that. I think…
…motion. Doc.892. Among other things, the Court found that “the parties and multiple deponents have reasonably relied on the Protective Order in giving testimony and producing documents including evidence of assault, medical records, and emails.” Id. at 6. Mr…
…and repeated sexual abuse after being recruited by Ghislaine Maxwell and Jeffrey Epstein when Giuffre was under the age of eighteen. Between 1999 and 2002, with the assistance and participation of Maxwell, Epstein sexually abused Giuffre at numerous locations . . . .” Dkt…
…given that the public identification of a stated objection, a geographical location (such as in an address), or even the non-party’s legal counsel (if she or he has one) could disclose the identity of the objecting non-party…
…giving rise to this defamation action . Among the statements at issue are a l legations of sexua l abuse of minors . Discovery has proceeded i nvolving these issues and those persons alleged l y involved . II . The Protective Order The…
…financier Jeffrey Epstein. (Accused of having sexual relations with multiple underage girls, Epstein ultimately pleaded guilty to just a single state charge of soliciting prostitution.) Case 1:15-cv-07433-LAP Document 363-11 Filed 08/11/16 Page…
…modification. In contrast, there are compelling reasons to maintain the Protective Order, the modification of which is “perilous for multiple reasons,” including that such modifications “undermine confidence in protective orders” and may well subject individuals to “annoyance, embarrassment, oppression, or…
…Doc.892, at 4-10. It found that “the parties and multiple deponents have reasonably relied on the Protective Order in giving testimony and producing documents including evidence of assault, medical records, and emails,” and “[t]hird-party witnesses have…
…2021 letter. See DE 237. They do so in multiple respects. First, the parties seek to clarify the term “non-party Does” as it appears in the January 6 Order. This purported ambiguity is just a pretext to again request…
…August 9, 2016, DE 352 at p. 1-2, Order directing Defendant to “capture all of the sent/received emails from Defendant’s multiple email accounts, including . . . any other email accounts Defendant has used in the past or currently uses…
… ARGUMENT I. Ms. Maxwell’s Motion to Dismiss Provides “Good Cause” to Stay Discovery A. The Pending Motion Cites Multiple, Independent Grounds for Dismissal A stay of discovery is particularly appropriate where, as here, a pending motion to dismiss…
…N.Y. Jan. 26, 2017) (complaint). Maxwell has now been accused of running or being involved in a child sex trafficking ring in multiple lawsuits. Maxwell’s involvement in sex trafficking is newsworthy on its face. Indeed, the Daily Mail…
…stay discovery pending resolution of her Motion to Dismiss. First, the Motion to Dismiss presents multiple, independent bases upon which this Court may dismiss the Complaint pursuant to Rule 12(b)(6). Each basis for dismissal is legally well-founded…
…As such, the Dershowitz Protective Order may fatally undermine this Court’s carefully constructed measures designed to protect from unnecessary public disclosure sensitive and private non-party information in the Maxwell materials. After rejecting multiple attempts by Mr. Dershowitz to…
…that Ms. Giuffre has lost access to her Hotmail.com account (multiple password 1 Case 1:15-cv-07433-RWS Document 207 Filed 06/13/16 Page 2 of 7 recovery attempts failed due to the aged, non-recoverable…
…of deposition of Alfredo Rodriguez on July 29 and August 7, 2009 designated Confidential under the Protective Order multiple and various cases. I declare under penalty of pe1jury that the foregoing is tme and coITect. Executed on Janua1y 27, 2017. …
…Ms. Giuffre alleges that Professor 14 Dershowitz has defamed her by calling her a serial liar who's 15 committed perjury as part of an extortion scheme against 16 multiple wealthy third parties and individuals. She uses those 17 words…
…Plaintiff’s attorneys and Alan Dershowitz, which she acknowledged were subject to confidentiality requirements. Likewise, in the Response to this Motion, Plaintiff includes multiple improper, irrelevant and misleading statements, demonstrating why protection of Ms. Maxwell’s personal financial information is…
…his Court’s protocol. These include: DE 228 (numerous Non-Parties); 229-1 (excerpt of deposition of Doe 151); DE 229-4 (deposition of Plaintiff including multiple Non- Party names); DE 229-10 (including Non-Parties); DEs 248, 249-4…
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