…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…
…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…
…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…
…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…
…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…
…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…
…any details about her ordeals two decades ago, she unquestionably continues to experience trauma similar to that of at least one other Non-Party Doe whose privacy and identity this Court protected with Plaintiff Virginia Guiffre’s consent. See Doc…
…the subpoena served on Ms. Ransome seeks documents that are wholly irrelevant to the underlying action including protected financial information and documents or communications between Sarah Ransome and her attorneys, which are protected by the attorney- client privilege and the…
…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…
…the subpoena served on Ms. Ransome seeks documents that are wholly irrelevant to the underlying action including protected financial information and documents or communications between Sarah Ransome and her attorneys, which are protected by the attorney- client privilege and the…
…Blando Court Reporting & Video, Inc. 1 INDEX OF EXHIBITS 2 INITIAL 3 DESCRIPTION REFERENCE 4 Exhibit 1 Authorization for the Release 7 5 and Disclo…
…which Ms. Maxwell is a target. First, Plaintiff claimed that the documents were protected by a non-existent “investigative privilege.” When Ms. Maxwell demonstrated that the “investigative privilege” does not exist, Plaintiff threw up the inapplicable “public interest” privilege, the…
…any details about her ordeals two decades ago, she unquestionably continues to experience trauma similar to that of at least one other Non-Party Doe whose privacy and identity this Court protected with Plaintiff Virginia Guiffre’s consent. See Doc…
…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…
…London WI J 6HE +44 (0) 777 875 5251 mob +7 903 363 5393 MocKBa Mo6nnbHb1fr 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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