…that he never saw any naked photos at Epstein’s Palm Beach mansion, the recently released video taken by the Palm Beach Police department during its investigation, reveals naked photos in a number of the common areas of Epstein’s…
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…brief 11 on this matter. 12 We wrote a letter to opposing counsel citing some 13 governing provisions of Microsoft's email policy that indicates 14 that due to inactivity they delete accounts after a certain 15 amount of time…
…"New York public policy as embodied in the Constitution and our current statutory scheme provides a mantle of protection for those who gather and report the news-and their confidential sources-that has been recognized as the strongest in the…
…law of the country that has the predominant or the most direct and compelling interest in whether [the] communications should remain confidential, unless that foreign law is contrary to the public policy of this forum.” Anwar v. Fairfield Greenwich Ltd.…
…whether Income was received by You or anyone else concerning such event, whether a police report was ever filed concerning such event and the outcome of any such case, as well as the address and location of any such event…
…P. 26(b)(4)(D). 4 There are four commonly articulated policy 3 Additionally, to the extent these non-testifying experts assist in the rendition of legal services, such as rendering opinions related to Defendant’s electronic discovery, those communications…
…8~ . 3,7.3, ,..448 ' ~ ~: E ;2 dJ 1_2:1 ., i. · (1983). The policy purposes 6f privilege in both jurisdictions also mi..r ~fn
…allegedly defamatory statements at issue. New York therefore has the predominate interest in whether these communications remain confidential. The similarity between New York and British attorney-client privilege demonstrates that no public policy conflict exists. Consequently, New York law applies…
…the law of the country that has the ‘predominant’ or ‘the most direct and compelling interest’ in whether those communications should remain confidential, unless that foreign law is contrary to the public policy of this forum.” 208 F.R.D…
…nature of this suit, which puts the legal advice defendants received directly in issue, the policy behind the privilege is outweighed by the necessity of disclosure and the privilege is inapplicable.”). Plaintiffs’ objections should be overruled, and they should be…
…news/ghislaine-maxwell-denied-inappropriate-action-by-jeffrey-epstein-in-newly-released-2016-deposition/ 232 https://www.washingtonexaminer.com/policy/courts/ghislaine-maxwell-repeatedly-pushed-back-on-epstein-sexual-misconduct-allegations-unsealed-deposition-revea 233 https://www.mynspr.org/post…
…all of which would be consistent with the policy Case 1:15-cv-07433-RWS Document 57-2 Filed 03/14/16 Page 12 of 30 underlying privilege and with a common sense application of that policy to the practicalities…
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…or relied upon” in a phone call with Plaintiff’s counsel. ...................................................................................... 1 B. RFP Nos. 2-3: Documents concerning “how” the defense obtained “police report(s).” ...............................................................................…
…that: It is the duty of the lawyer or law firm, … and government agents and police officers, not to release or authorize the release of non- public information or opinion which a reasonable person would expect to be disseminated…
… Attached hereto as Exhibit 3, is a true and correct copy of the Palm Beach Police Report. Case 1:15-cv-07433-LAP Document 1090-3 Filed 07/30/20 Page 2 of 4 6. Attached hereto as Exhibit…
…Second set of Requests for Production on April 14. Those Requests primarily concerned police reports about Plaintiff’s various contacts with law enforcement and how the defense was able to obtain those publicly-available documents (RFP’s 1-5, 19)…
…likely because there is none."). I disagree. Your latest produc6on includes a police report detailing the rape of a 14 year old child, my client. Other materials you produced include police records concerning my client while she was a minor…
…Second set of Requests for Production on April 14. Those Requests primarily concerned police reports about Plaintiff’s various contacts with law enforcement and how the defense was able to obtain those publicly-available documents (RFP’s 1-5, 19)…