giuffre-maxwell
gov.uscourts.nysd.447706.885.0
7 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.33
3 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.27
3 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.9
6 pg
…Gow
Managing Partner
ACUITY Reputation
23 Berkeley Square
London W1J 6HE
www.acuityreputation.com
The information contained in this e-mail and any attachments is confidential and may be privileged or otherwise
protected from disclosure…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.2
70 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.18.0
5 pg
…refers the Court to
her Memorandum of Law in Support of Motion to Dismiss wherein she argues as grounds for
dismissal both that the Complaint has various pleading deficiencies and that the alleged
defamatory statements are protected by not one…
giuffre-maxwell
gov.uscourts.nysd.447706.29.0
2 pg
…323, 339 (1974), the court held that “[t]his
sort of purely opnionated speech…is protected and not actionable as defamatory speech.” Id. In
dismissing the case, the court further noted that Cosby’s public denial of the claims…
giuffre-maxwell
gov.uscourts.nysd.447706.223.7
3 pg
…used under the rules and in the action.
2. Mr. Epstein objects to the Subpoena to the extent that it seeks or purports to require
production or disclosure of privileged or other protected matter. Mr. Epstein hereby asserts all
privileges…
giuffre-maxwell
gov.uscourts.nysd.447706.218.0
25 pg
…Law ................................................................ 7
B. All of the Information Sought by the Subpoena Is, At a Minimum,
Protected by the Qualified Privilege Under the Shield Law ....................... 9
1. The Info…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…the 25 interrogatory limit set by Rule 33.
Ms. Giuffre objects to Defendant’s First 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…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.21
11 pg
…Square
London WlJ 6HE
www.acuityreputation.com< http://www.acuityreputation .com/>
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…Giuffre’s lawyers and non-party Ms. Ransome. It is well settled
that documents relating to witness interviews are protected by the work product privilege. In
addition, Defendant wrongly argues that she is entitled to any communications and witness
interviews…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.22
22 pg
…England Number 908396
Ross Gow
Managing Partner
ACUITY Reputation
23 Berkeley Squa re
London WlJ 6HE
www.acuityreputation.com
The information contained in this e-mail and any attachments is confidential and may be privileged or
otherwise protected from disclosure…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.9
29 pg
…Giuffre’s lawyers and non-party Ms. Ransome. It is well settled
that documents relating to witness interviews are protected by the work product privilege. In
addition, Defendant wrongly argues that she is entitled to any communications and witness
interviews…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…information itself
(ii) These acts may be reqtJired only as directed in the order, and the privileged or protected, will enable the parties to asses.~ the claim.
order must protect a person who is neither a party nor a…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…the 25 interrogatory limit set by Rule 33.
Ms. Giuffre objects to Defendant’s First 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…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…Filed 03/23/16 Page 4 of 45
Ms. Giuffre objects to Defendant’s First 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…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…or tangible
things in a manner that, without revealing information itself privileged or protected, will
enable the parties to assess the claim.
An “unjustified failure to list privileged documents on the required log of withheld
documents in a timely and…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…com
s/ Laura A. Menninger
Laura A. Menninger
13
Case 1:15-cv-07433-RWS Document 71-6 Filed 03/23/16 Page 18 of 19
Authorization to Disclose Protected Health Information…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…Filed 03/31/16 Page 4 of 45
Ms. Giuffre objects to Defendant’s First 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…
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