…irrelevant to this action and not reasonably calculated to lead to the discovery of admissible evidence. Maxwell further objects to this Request to the extent it seeks documents or information protected by the attorney/client privilege, the work-product doctrine…
… Defendant’s Communication with Attorneys Philip Barden, Mark Cohen, and Brett Jaffe Are Protected by the Attorney-Client Communication Privilege (Entries 1, 2, 9 and 17) ………………………………………
…pursuant to the Court’s Order [DE 134] dated May 2, 2016.1 ARGUMENT Statements made by witnesses to law enforcement are protected by the public interest privilege, which “exists to encourage witnesses to come forward and provide information in…
… TABLE OF CONTENTS Page PRELIMINARY STATEMENT .................................................................................................... 1 ARGUMENT .....…
…publicly disclosed volumes of information related to her allegations, to claim that letters or emails from her lawyers or other documents sent to any law enforcement agency are protected by any privilege. Plaintiff lacks standing to raise the issue and …
…15-cv-07433-LAP Document 1320-18 Filed 01/03/24 Page 3 of 40 IV.COMMUNICATIONS WITH ATTORNEY JACK SCAROLA ARE COVERED BY A JOINT DEFENSE AGREEMENT AND ARE THUS PROTECTED BY ATTORNEY- CLIENT AND WORK-PRODUCTION PROTECTION....................................…
…including subparts, in violation of Rule 33. Ms. Giuffre objects to Defendant’s Second Set of Discovery Requests to the extent they seek information that is protected by any applicable privilege, including but not limited to, attorney client privilege, work…
…any identifying information, for example, their Social Security 21 number or an address be able to be protected for those that are 22 coming to testify. I know that makes it a little bit more 23 difficult, but if we…
…of Confidential Maxwell Materials Nothing material has changed since Mr. Dershowitz’s last application to receive materials protected by the Protective Order or otherwise filed under seal in the instant matter. The Court properly denied that application – which constituted Mr…
…Loretta A. Preska June 18, 2020 Page 2 of 2 the discovery materials that were protected by the protective order the parties supposedly “relied on” in making the production…
…Court or any Orders of the Court. 3. Ms. Maxwell objects to the Requests to the extent they seek documents or information protected by the attorney/client privilege, the work-product doctrine, Rule 408 of the Federal Rules of Evidence…
…This Court’s Order ............................................................................................23 5. Information About Ms. Giuffre’s Sexual Abuse is Protected by Florida Statutes ..................................................…
…addressee only. It contains information, which may be confidential and legally privileged and also protected by copyright. Unless you are the named addressee (or authorised to receive for the addressee) you may not copy or use it, or disclose it…
…1:15-cv-07433-LAP Document 1137-14 Filed 10/22/20 Page 3 of 40 IV.COMMUNICATIONS WITH ATTORNEY JACK SCAROLA ARE COVERED BY A JOINT DEFENSE AGREEMENT AND ARE THUS PROTECTED BY ATTORNEY- CLIENT AND WORK-PRODUCTION PROTECTION…
…Court or any Orders of the Court. 3. Ms. Maxwell objects to the Requests to the extent they seek documents or information protected by the attorney/client privilege, the work-product doctrine, Rule 408 of the Federal Rules of Evidence…
…15-cv-07433-LAP Document 1320-18 Filed 01/03/24 Page 3 of 40 IV.COMMUNICATIONS WITH ATTORNEY JACK SCAROLA ARE COVERED BY A JOINT DEFENSE AGREEMENT AND ARE THUS PROTECTED BY ATTORNEY- CLIENT AND WORK-PRODUCTION PROTECTION....................................…
…Generally, the work product privilege is waived when protected materials are disclosed in a manner which is either inconsistent with maintaining secrecy against opponents or substantially increases the opportunity for a potential adversary to obtain the protected information.” Id. at…
…personally identifiable information, such as a social security numbers, home addresses, personal email addresses or personal telephone numbers; (iii) protected health information, inclusive of physical and mental health records; and (iv) identifying information of sexual abuse victims, such as names…
…by intervenors, Judge Sweet found otherwise, i.e., that the case terminated on May 25, 2017, at which point “all protected information, including the Jane Doe Evidence, was to be returned to the original party, parties, non-party, or non…
…to unsealing and are seeking to protect their privacy and other interests. We respectfully submit that these interests can be protected by entry of an order granting Mr. Dershowitz’s request for the discrete pre-answer discovery he has requested…
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