…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) ………………………………………
…AUTHORITIES.......................................................................................................... ii INTRODUCTION ...........................................................................................................................1 ARGUMENT ...............................................................................…
…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 .....…
…14 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 …
…CONFIDENTIAL DEPOSITION OF DR. STEVEN W. OLSON Exhibit 1 Authorization for the Release 7 May 26, 2016 5 and Disclosure of Protected __________________________________________________ Heal…
…cv-07433-LAP Document 885 Filed 05/02/17 Page 3 of 7 Ms. Giuffre’s previous Requests for Production,1 they contain Court-ordered search terms, and they are not protected by any privilege, work product or otherwise. Accordingly…
…1 B. Ms. Maxwell’s Statement In Context Is Not Defamatory ................................... 3 II. MS. MAXWELL’S STATEMENTS ARE PROTECTED BY PRIVILEGE .......... 6 A. Qualified Privilege May Form the Basis for a Rule 12(b)(6) Dismissal ............. 6 B. Ms. Maxwell…
…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…
…Many of them also concern minors and a victim of sexual assault; therefore, they are protected by various state statutes. Ms. Giuffre requests that this Court maintain the confidentiality designations over these police reports and direct the Defendant to disclose…
…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…
…of this Court or any Orders of the Court. 3. Ms. Maxwell objects to the Interrogatories to the extent they seek information protected by the attorney/client privilege, the work-product doctrine, Rule 408 of the Federal Rules of Evidence…
…Gow Managing Partner ACUITY Reputation Jane Doe 2 Jane Doe 2 www.acuityreputation.com The information contained in this e-mail and any attachments is confidential and may be privileged or otherwise protected from disclosure…
…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…
…Managing Partner Jane Doe 2 Jane Doe 2 Jane Doe 2 www.acuityreputation.com The information contained in this e-mail and any attachments is confidential and may be privileged or otherwise protected from disclosure…
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