Found 28 results for “safe” in 157ms

gov.uscourts.nysd.447706.57.1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.57.1 26 pg

…Discovery — Privilege — Accident report by servants of railways board in pursuance of practice of board—Partly p prepared for safety purposes and partly for obtaining legal ^ advice in anticipation of legal proceedings—Whether latter purpose to be dominant for…

gov.uscourts.nysd.447706.1328.41.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1328.41 31 pg

…in its in camera review before ordering Defendant to produce them. Yet Dershowitz waited until after discovery closed and until after he was safe from receiving a notice of deposition in this matter, before he filed his intervention motion. Unsurprisingly…

gov.uscourts.nysd.447706.1201.1_1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1201.1_1 17 pg

…university, which she desperately wanted - and would win. The girls’ mother told me by phone that she had thought her daughters would 6 be safe under Epstein’s roof, not least because he phoned her to reassure her, and…

gov.uscourts.nysd.447706.1331.16.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1331.16 10 pg

…Okay. After speaking to the police or while speaking to the police, do you remember telling them that you're not safe because you're talking about this? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Yes. BY MR…

gov.uscourts.nysd.447706.1100.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1100.0 16 pg

…and not for any civil proceeding or any purpose other than the defense of this action; b) Shall be maintained in a safe and secure manner; c) Shall be reviewed and possessed by the Defendant in hard copy solely in…

gov.uscourts.nysd.447706.1218.22.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1218.22 31 pg

…in its in camera review before ordering Defendant to produce them. Yet Dershowitz waited until after discovery closed and until after he was safe from receiving a notice of deposition in this matter, before he filed his intervention motion. Unsurprisingly…

gov.uscourts.nysd.447706.1331.18.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1331.18 8 pg

… Okay. After speaking to the police or 16 while speaking to the police, do you remember 17 telling them that you're not safe because you're 18 talking about this? 19 MR. PAGLIUCA: Object to form and 20 foundation…

gov.uscourts.nysd.447706.15.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.15.0 29 pg

…the 10th Circuit has deemed it a “safe presumption” that Colorado Supreme Court would adopt the various provisions of the Restatement (Second) of Torts (1977) as part of “its common law of defamation” based on its decisions and Uniform Jury…

gov.uscourts.nysd.447706.1295.8.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1295.8 9 pg

…clearly asked solely for the purpose of embarrassing, intimidating and harassing a non-party already fearful for her safety and life based upon the abuse she suffered at the hands of Defendant and Epstein, abuse as to which she testified…

gov.uscourts.nysd.447706.1335.3.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1335.3 223 pg

…notice anything to my 20 law office for Virginia. She's had some safety 21 issues with respect to her location so we're not 22 going to be putting that on the record. 23 MS. BORJA: That's fine…

gov.uscourts.nysd.447706.1067.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1067.0 10 pg

…App’x 723, 725 (2d Cir. 2017) (noting generally that protection of ongoing investigations and safety of witnesses may be countervailing interests). However, Ms. Maxwell’s generalized assertion that there are ongoing criminal investigations is wholly insufficient to warrant sealing…

gov.uscourts.nysd.447706.503.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.503.0 21 pg

…particular v igilance . . in safeguarding the free press against undue inter ference ," and "prevent(ing] undue diversion of journalistic effort and disruption of press functions." 71 N.Y.2d at 528-29 (disc u ssing New York Constitution, article I, …

gov.uscourts.nysd.447706.68.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.68.0 17 pg

…witnesses. Regarding Ms. Giuffre’s own address, she is a child victim of sex trafficking. As a result of personal safety concerns, Ms. Giuffre disclosed her attorney’s address and agreed to accept service at that address. During the meet…

gov.uscourts.nysd.447706.1320.40.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1320.40 19 pg

…Royal Palm Beach (Florida) Police Department, the County Court in and for Palm Beach County (Florida), the Greenacres (Florida) Department of Public Safety, and the Fremont County (Colorado) Sheriff’s Office. 9. Employment records obtained from ET Employment Training and…

gov.uscourts.nysd.447706.1295.11.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1295.11 19 pg

…A at 199:3-23. It is axiomatic that any conversations between Ms. Ransome and Mr. Dershowitz in the presence of Jeffrey Epstein, a third party, are not protected by privilege. Safeco Ins. Co. of Am. v. M.E.S.…

gov.uscourts.nysd.447706.955.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.955.0 43 pg

…to encompass woman's decision whether or not to terminate her pregnancy, but that this right is not absolute in that the state may properly assert important interests in safeguarding health, in maintaining medical standards and in protecting potential life).…

gov.uscourts.nysd.447706.949.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.949.0 31 pg

…My client and my reporter write 16 about those things all the time. She writes about children. 17 She writes about public officials whose information needs to be 18 redacted for safety purposes. 19 But the bottom line, your Honor…

gov.uscourts.nysd.447706.63.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.63.0 22 pg

…known Prime Minister and other world leaders.” Plaintiff refused, claiming every applicable privilege, and additionally “because naming some such individuals would jeopardize her physical safety based on credible threats to the same (sic).” Menninger Decl. Ex. A at 12-13…

gov.uscourts.nysd.447706.1218.12.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1218.12 223 pg

…notice anything to my 20 law office for Virginia. She's had some safety 21 issues with respect to her location so we're not 22 going to be putting that on the record. 23 MS. BORJA: That's fine…

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