…to Documents Describing Sexual Abuse. ......................................................................................................4 III. Doe 97’s Objection Is Insufficient. .......................................................................5 IV. Doe 107’s Objection Should Be …
…2 of 20 TABLE OF CONTENTS PRELIMINARY STATEMENT .................................................................................................1 ARGUMENT ..............................................................................................................................3 I.…
…Maxwell objected to the second deposition, based in part on her privacy concerns about testifying to her adult consensual activity (id.); • Judge Sweet overruled Ms. Maxwell’s objections to the deposition, ruling that her “privacy concerns are alleviated by the…
…2016 that Ms. Maxwell must sit for a second deposition on eight topics all “relating to [her] own sexual activity” and “her knowledge of the sexual activity of others.” (DE 316-6 at 10) Judge Sweet overruled Ms. Maxwell’s…
…a non-existent “investigative privilege.” When Ms. Maxwell demonstrated that the “investigative privilege” does not exist, Plaintiff threw up the inapplicable “public interest” privilege, the assertion of which was overruled by your Honor on April 21, 2016. The Court ordered: …
…When Ms. Maxwell demonstrated that the “investigative privilege” did not exist, Plaintiff threw up the inapplicable “public interest” privilege, the assertion of which was overruled by the Court on April 21, 2016. The Court Ordered: “The criminal investigation. Any materials…
…giving Doe 171 ample notice to decide on what she wanted to do in the event the Court overruled her objection. Doe 171 has had ample time to appeal in a non-urgent basis and she has not done so…
…relevant. Ms. Giuffre respectfully requests that this Court direct Maxwell to produce all responsive documents for the time period from 1999 to the present.6 Defendant Maxwell has also asserted fundamentally improper general objections which should be overruled. Am. Rock…
…of this 20 production on -- you are going to have to -- well, wait a 21 minute. Let me put it this way. The objections to this 16 are 22 overruled except for the privilege. OK? 23 MS. MENNINGER: Your Honor…
…MCCAWLEY: I can make my record, and my 16 record is she's not going to be speaking with 17 respect to individuals' names that are named in 18 generalities in this document. 19 SPECIAL MASTER: Objection overruled. You 20…
…85. B. Dershowitz’s Present, Expanded Second (or Third) Bite at the Apple and Giuffre’s Acquiescence to the Same With his objections to the protocol overruled in Maxwell, and having already failed to circumvent it once in Dershowitz, Dershowitz…
…of this 20 production on -- you are going to have to -- well, wait a 21 minute. Let me put it this way. The objections to this 16 are 22 overruled except for the privilege. OK? 23 MS. MENNINGER: Your Honor…
…2016). Plaintiff objected to this interrogatory on the ground it requested pre-1999 medical information in “violat[ion]” of the Court’s ruling. The objection should be overruled. The issue 4 Plaintiff’s voluminous arguments and argumentative citations to case…
…MCCAWLEY: I can make my record, and my 16 record is she's not going to be speaking with 17 respect to individuals' names that are named in 18 generalities in this document. 19 SPECIAL MASTER: Objection overruled. You 20…
…generalized objections that discovery requests are vague, overly broad, or unduly burdensome are not acceptable, and will be overruled.”). Therefore, this Court should require Defendant to produce the documents she admits to withholding. 3. This Court Should Grant Plaintiff’s…
…withholding any documents based on “copyright” and “proprietary” objections. In fact, she did withhold those documents – until this Court overruled her objection on March 17th. (Transcript at 13-17). She then provided thousands of pages of supposedly “copyright protected” and…
…privilege in these circumstances would result in nothing more than the concealment of the truth. Plaintiffs’ objections on the basis of the attorney-client privilege should be overruled. 2. Plaintiffs Have Waived Their Right To Rely On The Work Product…
…9, 14,15,21,22,25, 32 and. 35 should be overruled. Plaintiffs did not raise relevancy and admissibility objections to Interrogatory Nos. 13 and 21. Similarly, Plaintiffs did not raise relevancy and admissibility objections to Requests for Production No…
…1247 at 20, Plaintiff only addresses Does 28, 97 and 144’s replies. The Court should overrule their objections.1 In its April 19, 2022, ruling concerning the first set of Non-Party Objectors, the Court ordered that certain documents…
…2016). Plaintiff objected to this interrogatory on the ground it requested pre-1999 medical information in “violat[ion]” of the Court’s ruling. The objection should be overruled. The issue 4 Plaintiff’s voluminous arguments and argumentative citations to case…
Comments