…See McCawley Decl. at Exhibit 2. Defendant demanded that Ms. Giuffre agree to a Protective Order before Defendant would agree to sit for her deposition. See McCawley Decl. at Exhibit 3, (E-mail from Laura Menninger stating: “We have not…
…v. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. --------------------------------------------------X DEFENDANT’S RESPONSE IN OPPOSITION TO MOTION FOR PROTECTIVE ORDER AND MOTION FOR THE COURT TO…
…or any person from whom discovery is sought may move for a protective order in the court where the action is pending…The court may for good cause issue an order to protect a party or person from annoyance…
…Page 1 of 45 EXHIBIT B Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 2 of 45 This document is CONFIDENTIAL under the Court’s Protective Order (DE 62) United States District Court …
…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 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 PLAINTIFF’S MOTION FOR PROTECTIVE ORDER AND TO DIRECT THE DEFENDANT TO DISCLOSE ALL INDIVIDUALS TO WHOM DEFENDANT HAS DISSIMINATED CONFIDENTIAL INFORMATION (DE 335) …
…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) …
…Under Rule 26(c) of the Federal Rules of Civil Procedure any party may move the court, for good cause shown, for a protective order regarding pretrial discovery “which justice requires to protect a party or person from annoyance, embarrassment…
…motion. Doc.892. Among other things, the Court found that “the parties and multiple deponents have reasonably relied on the Protective Order in giving testimony and producing documents including evidence of assault, medical records, and emails.” Id. at 6. Mr…
…v. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. --------------------------------------------------X DEFENDANT’S RESPONSE IN OPPOSITION TO MOTION FOR PROTECTIVE ORDER AND MOTION FOR THE COURT TO…
…Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF, VIRGINIA GIUFFRE’S RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION FOR PROTECTIVE ORDER REGARDING DEPOSITION OF DEFENDANT …
…motion. Doc.892. Among other things, the Court found that “the parties and multiple deponents have reasonably relied on the Protective Order in giving testimony and producing documents including evidence of assault, medical records, and emails.” Id. at 6. Mr…
…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…
…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…
…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…
…who was unable to produce the documents because of this Court’s Protective Order. 4 Case 1:15-cv-07433-LAP Document 1111 Filed 09/01/20 Page 5 of 14 ‘unduly delay and prejudice the adjudication of the…
…Defendant. MEMORANDUM OF LAW IN 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 …