…AUTHORITIES.......................................................................................................... ii INTRODUCTION ...........................................................................................................................1 ARGUMENT ...............................................................................…
…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 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…
…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 ..................................................…
…this case, including subparts, in violation of Rule 33. Ms. Giuffre objects to Defendant’s Discovery Requests to the extent they seek information that is protected by any applicable privilege, including but not limited to, attorney client privilege, work product…
…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…
…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…
…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…
…non-party Jane Doe No. 3 should be protected from having to be deposed in this matter or produce documents. Defendant’s campaign of threats and intimidation should not be condoned by this Court and Defendant’s subpoena should be…
…Paragraph 5: Paragraph 5 addresses who may view confidential information and Ms. Giuffre proposed adding to that list: “(h) any person (1) who authored or received the particular Protected Material; (2) who has or had at any point in time …
…Filed 01/05/24 Page 4 of 40 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…
…There, the court recognized that a non-party’s privacy interest should be protected “if this can be done in a manner consistent with the public’s reasonable interest in access to evidence relating to Plaintiffs’ equal protection claim.” Id…
…as demonstrated below, the Second Circuit does not provide a right of access to protected material when an individual seeks to use it solely for harm. B. These Are Not Judicial Documents and Therefore Should Not be Disclosed The Court…
…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…
…estate agent that she worked as a journalist The victim added that 'if [Maxwell] is out, I need to be protected', citing a phone call she received in the middle of the night threatening her two-year-old child. …
…2007) (“[A] person’s status as a juvenile sex abuse victim is clearly the type of ‘highly personal’ information that we have long recognized as protected by the Constitution from governmental dissemination absent a substantial government interest in disclosure.”). Moreover…
…1:15-cv-07433-LAP Document 66 Filed 03/23/16 Page 13 of 35 13 G3hdgium 1 THE COURT: You get it. 2 MS. MENNINGER: It is copyright and proprietary 3 protected. We're not going to produce it…
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