…event that those efforts prove unsuccessful, however, we would want to be afforded the opportunity to file an opposition to the Motion before it is decided. Accordingly, we respectfully request that the Court grant J Doe 12 permission, if necessary…
…objectors (see dkt. no. 1232) and the Miami Herald’s letter seeking an opportunity to respond to the objections (see dkt. no. 1321). The parties shall first file briefs addressing the objections of the following non-parties: Does 17, 53…
…Maxwell does not interpose objections to unsealing, subject to Non- Parties’ opportunity for notice to be heard. That the process for review of literally thousands of pages of sealed materials takes time to accomplish is not a reason to unseal…
…Rejecting Dershowitz’s position, the Court specifically structured the protocol to afford notice to those persons identified or otherwise interested in the Sealed Documents and to allow such affected persons the opportunity to object and be heard. As made clear…
…victim seeking restitution); In re Antrobus, 519 F.3d 1123 (10th Cir. 2008) (arguing for opportunity for victim to deliver a victim impact statement). His previous experience will be valuable to Ms. Giuffre as this case proceeds. Professor Cassell is…
…of its objection within 7 days of service of the Original Parties’ opposition.”). Additionally, as noted above, the Order for the first time provides the Herald with an opportunity to participate in the unsealing process. See DE 1233, at 1…
…Finally, the materials at issue should not be released publicly because the criminal court overseeing Ms. Maxwell’s criminal prosecution has not yet had an opportunity to determine whether the evidence will be admissible at trial or suppressed. I. As…
…will (1) undermine the careful unsealing process agreed to by the parties in Maxwell, and (2) infringe on the privacy or other countervailing interests against disclosure of the Does without their having notice and an opportunity to be heard. Accordingly…
…appeal (Doc. 1291), Doe 171 would like the opportunity to participate in a status conference with Your Honor and the parties to discuss her request to redact the personal and confidential information contained in the November 18, 2022 hearing transcript, …
…Generally, the work product privilege is waived when protected materials are disclosed in a manner which is either inconsistent with maintaining secrecy against opponents or substantially increases the opportunity for a potential adversary to obtain the protected information.” Id. at…
… however, Plaintiff wants the opportunity to demonstrate to the jury just how disingenuous Defendant’s argument is on this topic and in the interest of fairness believes she should have that opportunity. WHEREFORE, Plaintiff moves this Honorable Court to Order…
…ARGUMENT I. PLAINTIFF’S VIOLATION OF THIS COURT’S ORDER TO PRODUCE DOCUMENTS IS NOT AN OPPORTUNITY FOR HER TO RE-LITIGATE THE ISSUE. Plaintiff has been attempting to dodge the production of these documents for months. First, Plaintiff claimed…
…Corp. v. Deutsche Bank AG, 582 F. Supp. 2d 528 (S.D.N.Y. 2008) .................................................................................................... 9 Equal Emp't Opportunity Comm'n v. Nat'l Children's Ctr., Inc., 146 F.3d 1042 (D.C. Cir. 1998)......................................................................…
…Intervenor similarly requests sufficient notice sufficiently in advance of any closure to afford him the opportunity to assert common law and First Amendment right of access. Sincerely, Jay Marshall Wolman cc: All Counsel of Record (via…
…Counsel requests a brief extension of the period to Repl y to afford counsel the opportunity to adequately review and respond to Plaintiff's Responses as well as to review the new 800 pages of disclosures. The defense has not…
…assumed to have supported their papers with admissible evidence”). “If the rationale behind access is to allow the public an opportunity to assess the correctness of the judge’s decision, documents that the judge should have considered or relied 1…
…Parties.........................................6 II. THE COURT SHOULD USE ITS DISCRETION TO PRECLUDE INTRODUCTION OF TESTIMONY FROM A WITNESS MS. GIUFFRE HAS NOT HAD THE OPPORTUNITY TO CROSS EXAMINE. ............................................................................8 A. Allowing…
…rendition of legal services to the client). Some Florida courts have even recognized serious due process issues could be created by a procedure through which a client lost their privilege without an opportunity to be heard in the proceedings. See…
…able to perpetrate so many crimes against young females. These comments violate subsections (6) and (7) of the Rule. It appears that given any opportunity lawyers associated with the prosecution of this case will offer any opinion that damages Ms…
…CRITTON: 24 Q. Listen to my question. 25 Q. And you haven't had an opportunity to see 25 If he, Officer Recarey, had taken down Page 344 Page 346 1 your taped state…
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