…to documents that may be released, they should not receive a second opportunity to object thereafter. Allowing Non-Parties multiple opportunities to object to unsealing would set a precedent that would exponentially delay this process. The same is true of…
…unsealed documents “will be publicly available.” Finally, Defendant had the opportunity to propose this language to Plaintiff prior to submitting the form Notice to the Court, but failed to do so. This last-minute injection of language that is clearly…
…about her prior deposition, she cannot claim that she was questioned about these two emails. Ms. Giuffre deserves the opportunity to ask Defendant about them. II. ARGUMENT A. Discovery Concerning These Emails is Not Duplicative, and it is Highly Relevant…
…Filed 05/01/16 Page 2 of 3 respectfully requests that the Court stay its ruling for twenty (20) days to allow Ms. Giuffre an opportunity to consult with others about how to proceed. CONCLUSION Based upon the foregoing, Ms…
…Virginia’s father gave his blessing, believing his daughter was being handed the opportunity to learn a skill and to work for a wealthy and respectable employer. He drove her to Epstein’s pink mansion on the Palm Beach waterfront . …
…relevant to any reasonably foreseeable litigation. Third, if Plaintiff has concerns regarding deleted emails, Plaintiff has the opportunity to investigate this issue at Ms. Maxwell’s deposition. CONCLUSION For the reasons set forth above, Ms. Maxwell respectfully requests that this…
…such as 'whether the second deposition of the witness would be unnecessarily cumulative, whether the party requesting the deposition has had other opportunities to obtain the same information, and whether the burden of a second deposition outweighs its potential benefit.…
…the British Virgin Islands, in New Mexico, and in New York. They did not offer to prove these allegations or offer me an opportunity to dispute them; they simply inserted 6 them in the pleadings. While Ms. Giuffre’s attorneys…
…not have had a working understanding of the process in the first place.1 Ms. Giuffre argues that “[a]llowing Non-Parties multiple opportunities to object to unsealing would set a precedent that would exponentially delay this process.” (Dkt. no…
…her Email, and the Application of Robust, Mutually-Agreed Upon Search Terms Defendant has had multiple opportunities to negotiate a document production protocol or describe her document collection efforts on her own accord or when asked by Ms. Giuffre. Thus…
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