…supplement to her motion for an adverse inference instruction based on new information, follows. Most notably, Defendant claims to have run search terms and reviewed over 10,000 documents, but, remarkably, claims that not a single document - not one - is…
…supplement to her motion for an adverse inference instruction based on new information, follows. Most notably, Defendant claims to have run search terms and reviewed over 10,000 documents, but, remarkably, claims that not a single document - not one - is…
…The objections and responses to the RFPs are proper. ................................................ 1 A. RFP No. 1: Documents defense counsel “reviewed and/or relied upon” in a phone call with Plaintiff’s counsel. ...................................................................................... 1 B. RFP N…
…144), after it came to light that Giuffre’s counsel in Dershowitz possesses and has reviewed confidential and sealed materials from Maxwell, the Court subsequently directed the parties in Dershowitz to confer regarding “reasonable accommodation concerning Mr. Dershowitz’s requests…
…for Ms. Maxwell received Plaintiff’s proposed redactions. Counsel reviewed the proposed redactions to Ms. Maxwell’s 465-page deposition transcript and conferred with Plaintiff’s counsel regarding her proposed redactions during a telephone conference at 1 p.m. today…
…RFP No. 1 seeks documents Mr. Pagliuca allegedly ‘reviewed and/or relied upon’ in allegedly making statements stating that Plaintiff previously made false accusations of sexual assault.” (Br. at 5). (Emphasis original). How Defendant purports to distinguish between the actual…
…I've tried 14 to do that in our papers. But listening to opposing counsel 15 I'm concerned maybe she hasn't reviewed the documents we have 16 produced. We have clearly produced all of the media 17 communications…
…Ms. Giuffre is withholding documents based on her objections. 2. All Documents reviewed or relied upon in answering Interrogatory Nos. 1-14 above. Response to Request No. 2 Ms. Giuffre objects to this request in that defendant’s interrogatories violate…
…regarding sex abuse, sexual trafficking and acting as his “madam” to the stars. As proof, one need look no further than emails already reviewed by this Court. In an email sent by Epstein to Ms. Maxwell on January 25, 2015…
…intervention is a very rare bird indeed, so seldom seen as to be considered unique.”). CONCLUSION Having reviewed all of the arguments raised by TGP on appeal and finding them to be without merit, we AFFIRM the District Court’s…
…before it was filed in September of 2015, as evidenced by the email communications between Dershowtiz and Defendant the Court reviewed in its in camera review before ordering Defendant to produce them. Yet Dershowitz waited until after discovery closed and…
…LAP 162, 08/23/2023, Document 3560133, 1305 Filed Page4 08/23/23 Pageof 44 of 4 CONCLUSION Having reviewed all of the arguments raised…
…order articulated and applied the correct legal framework in its individualized review of the materials to be unsealed. CONCLUSION We have reviewed all of the arguments raised by Defendant-Appellant Maxwell on appeal and find them to be without merit…
…2016. It states: “Designation of a document as CONFIDENTIAL INFORMATION shall constitute a representation that such document has been reviewed by an attorney for the designating party, that there is a valid and good 4 Case 1:15-cv…
…underaged individuals in that directory 16 with their phone numbers. So we reviewed that with him. 17 He has testimony about the fact that the black book 18 was something that was kept in the course of their work. It…
…production. 22 Case 1:15-cv-07433-LAP Document 1320-37 Filed 01/03/24 Page 24 of 48 2. All Documents reviewed or relied upon in answering Interrogatory Nos. 1-14 above. Response to Request No. 2 Ms…
…25 SPECIFIC OBJECTIONS AND RESPONSES TO PLAINTIFF’S SECOND REQUESTS FOR PRODUCTION OF DOCUMENTS DOCUMENT REQUEST NO. 1 Produce all documents that Your attorneys reviewed and/or relied upon in the March 21, 2016, meet and confer discussion when Mr…
…117. During this soliloquy, Cassell details his and Edwards thought processes in assessing the claims, their evaluation of the evidence they reviewed, and all other information that he had to believe Plaintiff’s stories. He specifically refers to Plaintiff, their…
…to each document for ease of reference. PRELIMINARY STATEMENT On October 19, 2020, the Second Circuit affirmed this Court’s order unsealing the deposition materials included within the first set of motions the Court reviewed. Giuffre v. Maxwell, 827 F…
…public access to judicial documents. Specifically, on October 19, 2020, the Second Circuit affirmed this Court’s order unsealing the deposition materials included within the first set of motions the Court reviewed. Giuffre v. Maxwell, 827 F. App’x 144 …