…police reports, counsel for Ms. Giuffre immediately informed counsel for Defendant that she would like those documents to be treated as confidential under the Court’s Protective Order (DE 62). Significantly, two of the police reports identify Ms. Giuffre as…
…15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ REPLY IN SUPPORT OF PLAINTIFF’S MOTION FOR PROTECTIVE ORDER AND TO DIRECT THE DEFENDANT TO DISCLOSE ALL INDIVIDUALS TO WHOM DEFENDANT HAS DISSIMINATED CONFIDENTIAL INFORMATION (DE 335) …
…we found her and she will have to be deposed. The end 1 For the limited purpose of the Motion to Quash or for Protective Order and resolving the scope of the subpoena and any enforcement issues, Jane Doe No…
…SUPPORT OF PROPOSED INTERVENOR ALAN M. DERSHOWITZ’S MOTION FOR PERMISSIVE INTERVENTION AND UNSEALING OF JUDICIAL DOCUMENTS, OR IN THE ALTERNATIVE MODIFICATION OF PROTECTIVE ORDER Emery Celli Brinckerhoff & Abady LLP 600 Fifth Avenue, 10th Floor …
…Alternatively, to Strike Plaintiff’s Misrepresentations of Fact from her Reply In Support of Motion For Protective Order And To Direct The Defendant To Disclose All Individuals To Whom Defendant Has Disseminated (sic) Confidential Information (Doc. #388), and states as…
…the terms of the parties’ Protective Order. BACKGROUND On June 1, 2016, Ms. Giuffre issued her Third Revised Rule 26 Disclosure (the “Rule 26 Disclosure”) and marked the document “confidential” under the terms of the Protective Order. Defendant objected to…
…nos. 231, 232 in 19-cv-3377.) 1 Case 1:15-cv-07433-LAP Document 1187 Filed 01/06/21 Page 2 of 3 The Court does not read the protective order, as presently entered, to give the parties…
…cause a privacy harm to the designating party.” Doc.062 ¶ 8. If a non-designating party disagrees with a “confidential” designation, it is entitled under the Protective Order to object, giving notice identifying the information subject to the objection. Id. …
…(Doc. 1044).1 Nonparties on the list include (a) persons who produced or answered discovery based on the understanding that such discovery would be subject to the Protective Order, (b) persons who are identified as allegedly having engaged in sex…
…MILLER: Your Honor, we move to intervene and for 9 a modification of the protective order issued in this case. 10 There has been no objection made to our motion to 11 intervene, no objection to our motion to modify…
…Stat. § 39.202(6). Moreover, all records concerning Ms. Giuffre as a juvenile should be treated as confidential under the Protective Order because they concern a minor child, and therefore, are of a sensitive nature. Third, police reports concerning Ms…
…Plaintiff Virginia Giuffre to remove the confidentiality designation concerning the Ransome deposition—an action that would require modification of the Protective Order in this case —it also simultaneously remove the confidentiality designation from several related emails and attachments that the …
…Regardless, Mr. Epstein has been notified and consented to the production of the document pursuant to the terms 4 of the blanket protective order in the matter, which both parties have agreed is appropriate.1 He has stated he will…
…389 (1981). “In order to balance this protection of confidentiality with the competing value of public disclosure, however, courts apply the privilege only where necessary to achieve its purpose and construe the privilege narrowly because it renders relevant information undiscoverable…
…Sept. 4, 2020) (noting that protecting the identity of a sexual assault victim is not “a basis for withholding the document from the public in its entirety”). In McCord, the Court noted that courts frequently refer to sexual assault victims…