…for Unsealing Decided Motions. See DE 1224. We write to express our views regarding the parties’ respective submissions, as well as that offered by the Miami Herald. See DE 1225. As directed by the Second Circuit, this Court has made…
…which “‘honor’ killings are a real risk,” and “instead concluding [that] she . . . offered no more than generalized concerns of adverse publicity.” Doe 107 Br. at 2, 20. (internal quotation marks omitted). We assume the parties’ familiarity with the underlying facts…
…and submit this response based on the known portions of the documents as well as the parties’ public representations as to their contents. Intervenors incorporate by reference their arguments offered in response to the alleged “Countervailing Interests” identified by Ms…
…which “‘honor’ killings are a real risk,” and “instead concluding [that] she . . . offered no more than generalized concerns of adverse publicity.” Doe 107 Br. at 2, 20. (internal quotation marks omitted). We assume the parties’ familiarity with the underlying facts…
…Counsel for (4) Jeffrey Epstein, offered to accept service on or about April 11 but Plaintiff ignored that offer for more than six weeks. Plaintiff only began on June 12 any attempt to schedule that deposition in the Virgin Islands…
…could not do so without notice and an opportunity to be heard—only to find out that the testimony she offered with the district court’s blessing was the primary evidence against her in a criminal case and the basis…
…reasonable reliance 13 might apply. First, Professor Dershowitz has offered 14 unequivocally -- and subject only to rights he would enjoy 15 anyway, to get the Court to issue a further order changing the 16 status quo, but -- to join the…
…2019) (“documents merely shown to witnesses or otherwise discussed in Court but not offered into evidence” do not constitute judicial documents because “neither relevant to the performance of the judicial function nor useful in the judicial process”). 10 Case…
…which is next Friday. 3 We also offered to hold that deposition transcript confidential 4 until such time as the protective order could be issued so that 5 there is no barrier to us being able to take this deposition…
…the Confidential Materials was never filed with the Court. They have offered no reason why they have refused to return or destroy Confidential Materials “and all copies thereof” in their possession, custody and control that have not been filed with…
…the proposition that a trial court can violate a defendant’s due process rights when it fails to take precautions against the dissemination to jurors of evidence made available to the media that was never offered at trial. Maxwell Br…
…e.g., id. (“[C]ounsel for the [offending party] offered no explanation or excuse for their failure to comply with the rule's strictures. They did not attempt to defend the timeliness of their notice. The [offending party's] admitted…
…in an adversarial process. Although affidavits and depositions are offered “under penalty of perjury,” it is in fact exceedingly rare for anyone to be prosecuted for perjury in a civil proceeding.45 Similarly, 44 In relevant part, Rule 11 provides…
…which is next Friday. 3 We also offered to hold that deposition transcript confidential 4 until such time as the protective order could be issued so that 5 there is no barrier to us being able to take this deposition…
…case, the Supreme Court held the trial court violated defendant’s due process rights when it failed to take precautions to prevent dissemination of “evidence [made] available to the news media which was never offered in the trial.” Id. at…
…to why she could access one email account from Epstein’s private server, but not her other account from Epstein’s private server. No details are offered. Accordingly, Defendant fails to meet her burden under Rule 26(b)(2)(B…
…Ms. Giuffre respectfully requests that Court exclude from the case the excerpts from the deposition of Ms. Giuffre that have been offered by the Defendant. Dated: January 27, 2017 Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP …
…273 F.3d at 233. The references to the various attached exhibits were gratuitous and served no legitimate purpose related to the discovery dispute. During the course of this litigation Plaintiff offered, on more than one occasion, various iterations and…
…Counsel for (4) Jeffrey Epstein, offered to accept service on or about April 11 but Plaintiff ignored that offer for more than six weeks. Plaintiff only began on June 12 any attempt to schedule that deposition in the Virgin Islands…
…fails for the same reasons. CONCLUSION The Orders of a United States District Court Judge should be understandable and enforceable. The language proposed by Plaintiff renders the Protection Order neither. The Protective Order offered by Ms. Maxwell is neutral, understandable…