…51 (2d Cir. 2019) (explaining the same). This Document is akin to a summary exhibit under Federal Rule of Evidence 1006 — a mere aid prepared by the parties to assist the Court in carrying out its work. It includes the…
…including one claiming privilege, by ordering cross-examination. C Held, ruling accordingly: 1. Where a report was prepared pursuant to a statutory obligation the purposes of the instigator of the report were irrelevant. There should be no difference in principle…
…a named person, "Witness, interacted 2 and chat daily with underaged girls." 3 So this document is prepared by Mr. Rodriguez in an 4 effort to make money in connection with these Jane Doe cases. 5 Now, here's what…
…Decl., Ex. C at 312- 334 and Ex. D at 179- 89. Exhibit 13 was a document prepared by someone other than Ms. Maxwell, was not maintained by Ms. Maxwell and over which Ms. Maxwell had no control. Given the…
…22 Produce all Financial Statements prepared for or submitted to any Lender or Investor for the past three years by You personally or on Your behalf or on behalf of any entity in which You hold or held a controlling…
…apparently an 23 affidavit prepared by the FBI that's been provided to 24 Ms. Churcher by someone; I don't know whom, your Honor, but I'm 25 going to presume it was provided to Ms. Churcher by the …
…discovery motions, motions in limine, 1 Counsel for Intervenors has not seen these documents and submits this response based on the list of Decided Motions prepared by counsel for the Parties and Ms. Maxwell’s Objections. Case 1:15…
…After extensive discussion and coordinating a convenient time and place, as well as ultimately agreeing to a confidentiality agreement prepared by Maxwell’s attorney, at the eleventh hour Maxwell’s attorney informed plaintiff’s counsel that Maxwell’s mother was…
…After extensive discussion and coordinating a convenient time and place, as well as ultimately agreeing to a confidentiality agreement prepared by Maxwell’s attorney, at the eleventh hour Maxwell’s attorney informed plaintiff’s counsel that Maxwell’s mother was…
…a portion of Ms. Maxwell’s deposition. Exhibit 2 contains a “Flight Log Summary Chart” prepared by Plaintiff’s counsel and flight logs that contain the names of numerous Non-Party Does. Exhibit 3 purports to be 88 pages of…
…After extensive discussion and coordinating a convenient time and place, as well as ultimately agreeing to a confidentiality agreement prepared by Maxwell’s attorney, at the eleventh hour Maxwell’s attorney informed the undersigned that Maxwell’s mother was very…
…22 Produce all Financial Statements prepared for or submitted to any Lender or Investor for the past three years by You personally or on Your behalf or on behalf of any entity in which You hold or held a controlling…
…I 19 don't know what this is, it wasn't prepared by my department, 20 I've never looked at it. 21 And so whatever this document is has not been 22 authenticated by anyone. That's the first…
…22 Produce all Financial Statements prepared for or submitted to any Lender or Investor for the past three years by You personally or on Your behalf or on behalf of any entity in which You hold or held a controlling…
…22 Produce all Financial Statements prepared for or submitted to any Lender or Investor for the past three years by You personally or on Your behalf or on behalf of any entity in which You hold or held a controlling…
…Ms. Giuffre is entitled to have the Court compel production of communications and documents related to these disclosures. Some of those documents are specifically identified in the privilege logs prepared by Defendant, while Defendant has withheld other documents and communications…
…Decl., Ex. C at 312- 334 and Ex. D at 179- 89. Exhibit 13 was a document prepared by someone other than Ms. Maxwell, was not maintained by Ms. Maxwell and over which Ms. Maxwell had no control. Given the…
…Brief submitted by Churcher in support of her motion to quash the subpoena served on her; (2) emails between Churcher and Giuffre submitted in connection with the same motion; and (3) a draft of a manuscript prepared by Giuffre submitted…
…7. It is not. The document was prepared by Ms. Giuffre in an attempt to seek legal advice at the request of her attorneys and to convey information to them to assist in forming legal opinions and rendering legal advice…
… prepared by Attorney-Client Ghislaine …
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