Found 75 results for “opportunity” in 226ms

gov.uscourts.nysd.447706.1073.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1073.0 22 pg

…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…

gov.uscourts.nysd.447706.66.0_1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.66.0_1 35 pg

…imposed upon you. I'm sorry 3 about the inconvenience that you have imposed upon me. 4 But having said all of that, this really is the first 5 time that we've had an opportunity, I think, to get…

gov.uscourts.nysd.447706.1135.0_6.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1135.0_6 1 pg

…Maxwell believes that her proposed additional redactions comport with the Court’s direction that Non-Parties be given the opportunity to review and object before any information identifying their identity or any conduct attributed to them (including as either an…

gov.uscourts.nysd.447706.1218.39.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1218.39 36 pg

…imposed upon you. I'm sorry 3 about the inconvenience that you have imposed upon me. 4 But having said all of that, this really is the first 5 time that we've had an opportunity, I think, to get…

gov.uscourts.nysd.447706.1097.0_1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1097.0_1 6 pg

…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…

gov.uscourts.nysd.447706.637.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.637.0 12 pg

…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…

gov.uscourts.nysd.447706.1331.18.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1331.18 8 pg

…PAGLIUCA: If you can just do a little 20 pause in between his question and your answer. 21 I need an opportunity to object to any form or 22 foundation problem with his question. 23 THE WITNESS: Sure. 24 MR…

gov.uscourts.nysd.447706.492.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.492.0 9 pg

…documents are highly relevant. Whatever Defendant argues about her prior deposition, she cannot claim that she was questioned about Ms. Giuffre deserves the opportunity to ask Defendant about them. II. ARGUMENT A. Discovery Concerning is Not Duplicative, and it is…

gov.uscourts.nysd.447706.610.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.610.0 3 pg

…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…

gov.uscourts.nysd.447706.686.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.686.0 17 pg

…Trafficking Organization Is Also Admissible Under Rule 404(b) to Show Motive and Plan. .........................................................................................................................7 C. Evidence of Defendant’s Involvement in Epstein’s Sex Trafficking …

gov.uscourts.nysd.447706.1247.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1247.0 25 pg

…See Amodeo, 71 F.3d at 1051 (“Similarly, a court may consider whether the nature of the materials is such that there is a fair opportunity for the subject to respond to any accusations contained therein.”). Accordingly, Doe 144’s…

gov.uscourts.nysd.447706.1320.18.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1320.18 40 pg

…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…

gov.uscourts.nysd.447706.1078.1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1078.1 8 pg

…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…

gov.uscourts.nysd.447706.1218.49.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1218.49 27 pg

…. have reason to believe that you have personally observed Jeffrey Epstein in the presence of underage females, and we would like the opportunity to question you under oath about those observations.” Id at SCAROLA 016567. I replied that “If you…

gov.uscourts.nysd.447706.1254.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1254.0 18 pg

…asserted privacy interests that they 14 contend weigh against unsealing. These objecting Does have 15 been afforded the opportunity to respond to the written 16 positions of the parties and the Herald and some, but not all 17 of them…

gov.uscourts.nysd.447706.1328.5.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1328.5 45 pg

…above is in the possession of Defendant’s agent, who caused the false statements to be issued to various media outlets. Ms. Giuffre has not had the opportunity to depose Maxwell’s agent Ross Gow; therefore, this answer remains incomplete…

gov.uscourts.nysd.447706.1218.14.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1218.14 32 pg

…the record in the CVRA Action, these allegations were not sealed; instead, they were filed publicly without any evidence to support them and without affording Professor Dershowitz an opportunity to dispute them. Id. Although Ms. Giuffre elaborated these false allegations…

gov.uscourts.nysd.447706.824.0_2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.824.0_2 47 pg

…McCAWLEY: Your Honor, if I could, I'd like the 8 opportunity -- because there are only a few of the witnesses 9 that fall into this category -- 10 THE COURT: Okay. That's one thing. Let's sort of 11…

gov.uscourts.nysd.447706.1201.10_1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1201.10_1 27 pg

…of the allegations posited by reporter Vicky Ward. Plaintiff is not permitted to re-depose Ms. Maxwell on issues already covered, or which she had the opportunity to cover, in the first 7-hour deposition, particularly in light of the …

gov.uscourts.nysd.447706.1078.5.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1078.5 161 pg

…finally broke down. She began moving uneasily in her chair as the judge said the evidence against her was ‘strong’. When Judge Nathan said a ‘combination of factors’ showed she had the ‘motive and opportunity’ to flee before her trial…

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