…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…
…Accordingly, the Court should enter a protective order and bar enforcement of the subpoena. FACTUAL BACKGROUND Defendant has issued a subpoena for the production of all Ms. Giuffre’s documents associate with her iCloud email account and all emails associated…
…of 17 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------X .. ............................................. VIRGINIA L. GIUFFRE, …
…of 17 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------X ............................................. VIRGINIA L. GIUFFRE, Plaintiff, v. …
…those accounts. Accordingly, the Court should enter a protective order and bar enforcement of the subpoena. FACTUAL BACKGROUND Defendant has issued a subpoena for the production of all Ms. Giuffre’s documents associate with her live.com email account, Hotmail…
…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…
…confidential and implicates Ms. Maxwell’s privacy interests. To the extent such information is relevant and discoverable in this action, Ms. Maxwell will produce such materials subject to an appropriate protective order pursuant to Fed. R. Civ. P. 26(c)…
…Objecting Does” a forum to deny their involvement with Epstein.4 In the alternative, if the Court believes that a motion to modify the Protective Order 2 Oversight Committee Releases Epstein Records Provided by the Department of Justice (Sept. 2…
…confidential and implicates Ms. Maxwell’s privacy interests. To the extent such information is relevant and discoverable in this action, Ms. Maxwell will produce such materials subject to an appropriate protective order pursuant to Fed. R. Civ. P. 26(c)…
…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…
…confidential and implicates Ms. Maxwell’s privacy interests. To the extent such information is relevant and discoverable in this action, Ms. Maxwell will produce such materials subject to an appropriate protective order pursuant to Fed. R. Civ. P. 26(c)…
…party. Without waiving such objections, a copy of non-party Sarah Ransome’s retainer agreement is attached hereto as RANSOME_000016, which should be treated as Confidential pursuant to the parties’ Protective Order. Ms. Ransome reserves the right to supplement…
…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…
…party. Without waiving such objections, a copy of non-party Sarah Ransome’s retainer agreement is attached hereto as RANSOME_000016, which should be treated as Confidential pursuant to the parties’ Protective Order. Ms. Ransome reserves the right to supplement…
…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…
…under seal at this time, the Government will not be aware of Epstein's disclosure of materials, much less be in position to even file a motion to attempt alter the protective order. In such circumstances, Epstein faces no "real…
…party. Without waiving such objections, a copy of non-party Sarah Ransome’s retainer agreement is attached hereto as RANSOME_000016, which should be treated as Confidential pursuant to the parties’ Protective Order. Ms. Ransome reserves the right to supplement…
…J. Doe have entirely failed to meet that burden. 3 Case 1:15-cv-07433-LAP Document 994 Filed 10/02/19 Page 4 of 14 Category 1: Motions to Compel and Related Motions for Protective Orders Ms. Maxwell…
…asked for more specific details about what information Ms. Maxwell hoped to elicit from Ms. Churcher, Maxwell’s counsel stated that she could not share any further details in light of the protective order entered in this case. Id. ¶ 3. …