gov.uscourts.nysd.447706.1328.41.pdf PDF
…Document 1328-41 Filed 01/05/24 Page 2 of 31 TABLE OF CONTENTS Page TABLE OF AUTHORITIES ........................................................................…
Found 110 results
for “procedural”
in 246ms
gov.uscourts.nysd.447706.1331.27.pdf PDF
…11 Defendant Ghislaine Maxwell, through counsel, submits this Response to plaintiff’s “Motion to Compel All Work Product and Attorney Client [sic] Communications with Philip Barden” (Doc.637). PROCEDURAL BACKGROUND On February 24, 2016, we served on plaintiff’s counsel…
gov.uscourts.nysd.447706.1218.14.pdf PDF
…10th Floor New York, New York 10020 (212) 763-5000 TABLE OF CONTENTS PAGE NO. TABLE OF AUTHORITIES .............…
gov.uscourts.nysd.447706.1332.15.pdf PDF
…as Jeffrey Epstein and Leslie Groff, cannot challenge this Court’s Protective Order. Therefore, the Court should summarily deny this motion. PROCEDURAL HISTORY On March 18, 2016, this Court entered a Protective Order (DE 62) for the privacy of the…
gov.uscourts.nysd.447706.1218.22.pdf PDF
…Document 1218-22 Filed 07/15/21 Page 2 of 31 TABLE OF CONTENTS Page TABLE OF AUTHORITIES ........................................................................…
gov.uscourts.nysd.447706.1328.6.pdf PDF
…of 32 TABLE OF CONTENTS PAGE NO. TABLE OF AUTHORITIES ...................................................................................................... iii-v PRELI…
gov.uscourts.nysd.447706.1332.11.pdf PDF
…Ghislaine Maxwell, through counsel, submits this Surreply in opposition to plaintiff’s “Motion to Compel All Work Product and Attorney Client [sic] Communications with Philip Barden” (Doc.637). INTRODUCTION Procedurally, plaintiff’s Motion to Compel is a mess. The motion…
gov.uscourts.nysd.447706.1304.0.pdf PDF
…after January 1, 2007, is permitted and is governed by Federal Rule of Appellate Procedure 32.1 and this Court’s Local Rule 32.1.1. When citing a summary order in a document filed with this Court, a party…
gov.uscourts.nysd.447706.1303.0.pdf PDF
…after January 1, 2007, is permitted and is governed by Federal Rule of Appellate Procedure 32.1 and this Court’s Local Rule 32.1.1. When citing a summary order in a document filed with this Court, a party…
gov.uscourts.nysd.447706.1206.13.pdf PDF
…writing a letter to the court (as was the case here), insinuate itself into a private civil lawsuit between others. The proper procedure, as the government should know, was either to subpoena the deposition transcripts for use in a pending…
gov.uscourts.nysd.447706.1069.0.pdf PDF
…without 20 access to the entirety of the record in Giuffre v. Maxwell, the 21 procedural history, but when the Second Circuit spoke with 22 regard to this issue, it was very clear that there had been no 23 effective…
gov.uscourts.nysd.447706.1073.0.pdf PDF
…her That she relied on the Protective Order in answering questions, or refusing to answer questions, is obvious from the procedural posture of the case: • March 2, 2016 (DE 38): Defendant moved for a Protective Order, citing Plaintiff’s anticipated…
gov.uscourts.nysd.447706.1166.0_1.pdf PDF
…enforceable, witnesses relying upon such orders will be inhibited from giving essential testimony in civil litigation, thus undermining a procedural system that has been successfully developed over the years for disposition of civil disputes. 594 F.2d at 295–96…
gov.uscourts.nysd.447706.1332.3.pdf PDF
…entitled to present those changed circumstances - to the Court. In an effort to deflect attention from the merits of attorney-client issues, Defendant raises the procedural argument that somehow Ms. Giuffre has failed to provide an appropriate certificate of conferral…
gov.uscourts.nysd.447706.955.0.pdf PDF
…have moved pursuant to Federal Rule of Civil Procedure 24 to intervene in this defamation action brought by plaintiff Virginia Giuffre ("Giuffre" or the "Plaintiff") against defendant Ghislaine Maxwell ("Maxwell" or the "Defendant") and to unseal all of the documents…
gov.uscourts.nysd.447706.63.0.pdf PDF
…look foolish on videotape for not remembering the contents of documents that relate back to witnesses and events occurring more than 17 years ago. The Federal Rules of Civil Procedure are designed to preclude such litigation by ambush and surprise…
gov.uscourts.nysd.447706.634.0_2.pdf PDF
…prejudice. 15 First of all, simply permitting a deposition of this 16 late-disclosed witness does not cure the significant prejudice 17 to Ms. Maxwell based on the facts and procedural posture of 18 this case. The deposition, your Honor…
gov.uscourts.nysd.447706.1137.15_2.pdf PDF
…In 2011, Jack Scarola, representing Brad Edwards in the Epstein v. Edwards case, faced procedural impediments to obtaining a sworn deposition from a member of the British Royal family. Accordingly, he publicly invited the voluntary testimony of Prince Andrew, explaining…
gov.uscourts.nysd.447706.1078.0.pdf PDF
…be inhibited from giving essential testimony in civil litigation, thus undermining a procedural system that has been successfully developed over the years for disposition of civil differences. In short, witnesses might be expected frequently to refuse to testify pursuant to …
gov.uscourts.nysd.447706.49.0.pdf PDF
…1(A), Plaintiff attaches correspondence between counsel while misrepresenting the facts relating to those communications. The Law Under Rule 26(c) of the Federal Rules of Civil Procedure any party may move the court, for good cause shown, for a…
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