…15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ REPLY IN SUPPORT OF NON-PARTY’S MOTION FOR PROTECTIVE ORDER AND OPPOSITION TO DEFENDANT’S COMBINED MOTION TO COMPEL NON-PARTY WITNESS TO PRODUCE DOCUMENTS AND RESPOND TO DEPOSITION TABLE…
…15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ REPLY IN SUPPORT OF NON-PARTY’S MOTION FOR PROTECTIVE ORDER AND OPPOSITION TO DEFENDANT’S COMBINED MOTION TO COMPEL NON-PARTY WITNESS TO PRODUCE DOCUMENTS AND RESPOND TO DEPOSITION TABLE…
…Defendant. ________________________________/ REPLY IN SUPPORT OF NON-PARTY’S MOTION FOR PROTECTIVE ORDER AND OPPOSITION TO DEFENDANT’S COMBINED MOTION TO COMPEL NON-PARTY WITNESS TO PRODUCE DOCUMENTS AND RESPOND TO DEPOSITION Case 1:15-cv-07433-LAP Document 1332…
…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) …
…cv-07433-RWS GHISLAINE MAXWELL, Defendant. --------------------------------------------------X Defendant’s Combined Motion To Compel Non-Party Witness To Produce Documents and Respond To Deposition Questions, And Response to Motion for Protective Order for Non-Party…
…that the Defendant may be selling her assets in New York and transferring the money outside the jurisdiction. Accordingly, Defendant’s motion for a protective order should be denied.1 I. PRELIMINARY STATEMENT As recounted by Defendant (DE 370 at…
…Defendant. ________________________________/ REPLY IN SUPPORT OF NON-PARTY’S MOTION FOR PROTECTIVE ORDER AND OPPOSITION TO DEFENDANT’S COMBINED MOTION TO COMPEL NON-PARTY WITNESS TO PRODUCE DOCUMENTS AND RESPOND TO DEPOSITION Case 1:15-cv-07433-LAP Document 1332…
…in opposition to Proposed Intervenor Alan M. Dershowitz’s Motion for Permissive Intervention and Unseal of Judicial Documents, or in the Alternative Modification of the Protective Order. 3. I am the Ronald N. Boyce Presidential Professor of Criminal Law and…
…in opposition to Proposed Intervenor Alan M. Dershowitz’s Motion for Permissive Intervention and Unseal of Judicial Documents, or in the Alternative Modification of the Protective Order. 3. I am the Ronald N. Boyce Presidential Professor of Criminal Law and…
…cv-07433-RWS GHISLAINE MAXWELL, Defendant. --------------------------------------------------X Defendant’s Combined Motion To Compel Non-Party Witness To Produce Documents and Respond To Deposition Questions, And Response to Motion for Protective Order for Non-Party…
…referee or resolve in any way. I am only asking that the Court refuse to allow its Protective Order, which was entered based upon a stipulation that explicitly contemplated that the Order might be modified, from being used to prevent…
…referee or resolve in any way. I am only asking that the Court refuse to allow its Protective Order, which was entered based upon a stipulation that explicitly contemplated that the Order might be modified, from being used to prevent…
…Bates-stamped GIUFFRE005607 through GIUFFRE005613, are being produced pursuant to Defendant's Request for Production. Certain of the documents within this production have been designated as CONFIDENTIAL in accordance with your proposed Protective Order. Please treat these documents accordingly. This…
…Bates-stamped GIUFFRE005607 through GIUFFRE005613, are being produced pursuant to Defendant's Request for Production. Certain of the documents within this production have been designated as CONFIDENTIAL in accordance with your proposed Protective Order. Please treat these documents accordingly. This…
…J., concurring) (noting "overriding policy in favor of enforcing the civil protective order against federal prosecutor's request for deposition transcripts”, and holding "[A] plaintiff in a civil litigation is bound by the terms of an agreement he has made…
…Bates-stamped GIUFFRE005607 through GIUFFRE005613, are being produced pursuant to Defendant's Request for Production. Certain of the documents within this production have been designated as CONFIDENTIAL in accordance with your proposed Protective Order. Please treat these documents accordingly. This…
…referee or resolve in any way. I am only asking that the Court refuse to allow its Protective Order, which was entered based upon a stipulation that explicitly contemplated that the Order might be modified, from being used to prevent…
…might foreshorten the 20 hearing on this topic. As Your Honor is aware, at the time 21 plaintiff filed a motion for a protective order about 22 Ms. Ransome's discovery, I had been in the process of trying to …
…Epstein or his associates, or (b) from the time frame 2006-07. Any privacy concerns can be alleviated based on the protective order entered in this case. F. Request 18: Driver’s License Response to Request No. 18 promised that…
…Epstein or his associates, or (b) from the time frame 2006-07. Any privacy concerns can be alleviated based on the protective order entered in this case. F. Request 18: Driver’s License Response to Request No. 18 promised that…