…and sound recordings of any nature. "Docwnent" also means all copies which are not identical to the original document as originally written, typed or otherwise prepared. The term "Document" shaU also include alJ documents of any nature that have been…
…and sound recordings of any nature. “Document” also means all copies which are not identical to the original document as originally written, typed or otherwise prepared. The term “Document” shall also include all documents of any nature that have been…
…and “recordings” as set forth in the Federal Rules of Evidence, including but not 2 Case 1:15-cv-07433-RWS Document 17-1 Filed 12/01/15 Page 3 of 13 limited to, originals or copies where originals…
…graphic and oral records and representations of any kind, and electronic “writings” and “recordings” as set forth in the Federal Rules of Evidence, including but not limited to, originals or copies where originals are not available. Any document with any…
…name and address of each of the addresses and/or individual to whom the Document was distributed, if any; (f) the title (or position) of its author; (g) type of tangible object, e.g., letter, memorandum, telegram, chart, report, recording…
…ARGUMENT .................................................................................................................................. 1 I. PLAINTIFF’S PRODUCTION OF KEY DOCUMENTS AFTER HER DEPOSITION NECESSITATES ADDITIONAL EXAMINATION ............................................................. 3 A. Plai…
…3, 4, 6, 17, 32 and 37) x documents relating to various topics include massages (RFP 5 and 29), travel records (RFPs 8, 9, 14 and 39), a civil deposition in 2010 (RFP 19), and Ms. Maxwell’s professional affiliation…
…also inclu d e allped iatric record s from birth: “Id entify any H ealthC are P rovid erfrom who Y ou received any treatmentforany physical, 2 Case 1:15-cv-07433-LAP Document 441 Filed 09/21/16…
…of the information sought. She is the only person who can provide the following information and documents: x The 24 page fabricated diary, and testimony on when and why it was created5 x Notes, transcriptions, tape recordings, and memorandum from…
…Doe 1 nor Doe 2 requested Excerpts under the Protocol, the Original Parties submitted their own briefs, and the Court ruled that the first five motions, including portions of those documents mentioning Doe 1 or Doe 2, should be unsealed…
…paragraph 2(f) of the Protocol, which addresses the situation in which a Non-Party does not object to a document’s unsealing, be changed to provide the Original Party objecting to unsealing (i.e., Defendant) with an automatic right…
…Jenna -----Original Messag e---- From: Sharon [email protected] Sent: Monday, 7 March 2011 6:22 PM To : Virginia Giuffre Page 1 of 69 GIUff RE00372 0 CONflDENTIAL Case 1:15-cv-…
…Original party “may file an opposition stating the reasons why any Sealed Item should be unsealed” (¶ 2(d)) and “any Original Party may file its own objection to unsealing/unredacting” (¶ 2(e)). Case 1:15-cv-07433-LAP Document…
…and oral records and representations of any kind, and electronic "writings'' and ·'recordings" as set fo11h in the Federal Rules of Evidence, including but not limited to, originals or copic;s where originals are not available. i\ny document -with…
Case 1:15-cv-07433-LAP Document 1327-15 Filed 01/05/24 Page 1 of 5 EXHIBIT C Case 1:15-cv-07433-LAP Document 1327-15 Filed 01/05/24 Page 2 of 5 From: Laura Menninger…
Case 1:15-cv-07433-LAP Document 1327-14 Filed 01/05/24 Page 1 of 4 EXHIBIT B Case 1:15-cv-07433-LAP Document 1327-14 Filed 01/05/24 Page 2 of 4 From: Laura Menninger…
…original disclosures. See id., Ex. G. On March 8, defense counsel again wrote and detailed additional deficiencies in the initial disclosures, in particular, her client’s statements to law enforcement, her client’s prior deposition testimony, and the many documents…
Case 1:15-cv-07433-LAP Document 1327-16 Filed 01/05/24 Page 1 of 6 EXHIBIT D Case 1:15-cv-07433-LAP Document 1327-16 Filed 01/05/24 Page 2 of 6 From: Laura Menninger…
…event, Ms. Maxwell may elicit testimony and obtain evidence on that issue directly from Ms. Roberts herself (or from her bank records and other documents). Further evidence of payments to Ms. Roberts (or contracts that Ms. Roberts entered into), if…
… Case 1:15-cv-07433-RWS Document 71-2 Filed 03/23/16 Page 17 of 45 g. for each such Health Care Provider, please execute the medical and mental health records release attached hereto as Exhibit A. Response…
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