gov.uscourts.nysd.447706.1295.10.pdf PDF
…hobby, 3 really. 4 Q. Are you employed? 5 A. Nope. 6 Q. Do you have any source of 7 income? 8 A. My partner -- 9 MR. GUIRGUIS: I'm going to 10 object to that. Income is out. 11 …
…hobby, 3 really. 4 Q. Are you employed? 5 A. Nope. 6 Q. Do you have any source of 7 income? 8 A. My partner -- 9 MR. GUIRGUIS: I'm going to 10 object to that. Income is out. 11 …
…TO SHOW THAT CHURCHER WAS NOT ENGAGED IN PROTECTED NEWSGATHERING ACTIVITY ........................ 3 A. The “Primary Relationship” Between Churcher and Plaintiff Was Reporter and Source ...................................................................…
…this non-party which information is being sought only for the purposes of harassment. The witness answered that the source of her current income is her partner. She should not be required to provide any additional information in this regard…
…11 B. Churcher’s documents and testimony are critical to Ms. Maxwell’s truth defense and Plaintiff’s claims ............................................................................................................ 15 C. Churcher’s information cannot be obtained from an alternative source. ..................…
…TO SHOW THAT CHURCHER WAS NOT ENGAGED IN PROTECTED NEWSGATHERING ACTIVITY ........................ 3 A. The “Primary Relationship” Between Churcher and Plaintiff Was Reporter and Source ...................................................................…
…21 14. Ms. Giuffre Has Not Refused To Produce Any Documents On The Grounds That They Are Available From Another Source ..............................22 15. Defendant’s Interrogatories Are Improper Under Local Rule 33.3.................22 16. …
…TO SHOW THAT CHURCHER WAS NOT ENGAGED IN PROTECTED NEWSGATHERING ACTIVITY ........................ 3 A. The “Primary Relationship” Between Churcher and Plaintiff Was Reporter and Source ...................................................................…
…life and finances from 2015 to present, including all documents “related to” her: tax returns, W-2 or any other source of income statements for her or any entity in which she holds an interest; Id. at RFP 23…
…hobby, 3 really. 4 Q. Are you employed? 5 A. Nope. 6 Q. Do you have any source of 7 income? 8 A. My partner -- 9 MR. GUIRGUIS: I'm going to 10 object to that. Income is out. 11 …
…life and finances from 2015 to present, including all documents “related to” her: tax returns, W-2 or any other source of income statements for her or any entity in which she holds an interest; Id. at RFP 23…
…broad and unduly burdensome, and seeks information that is not relevant to this case. 10. Identify any Income from any source other than Your Employment that You have received from January 1, 1996 until the present, including the Person or…
…nor duplicative of other information already disclosed in this case, (b) the fact the information can be obtained from other sources, 1 Plaintiff flatly mis-represents to the Court that Ms. Maxwell “refused” to answer the questions posed to her…
…cv-07433-LAP 9LGHR,QF Document 1328-30 Filed 01/05/24 Page 32 of 40 1 A Because I wasn't told any different. 2 Q Do you know where any -- any source of 3 that information came from…
…extent it calls for information that exists within the public domain, the internet or in public court records and which are equally available to both parties and can be obtained from some other source that is more convenient, less burdensome…
…1:20-cr-00330-AJNDocument Document1100-1 36 Filed Filed 07/30/20 08/10/20Page Pag…
…Ms. Giuffre worked as a receptionist and earned approximately $20/hr. 10. Identify any Income from any source other than Your Employment that You have received from January 1, 1996 until the present, including the Person or entity providing such…
…LAP Court Reporting Document & Video, 1257-22 Filed Inc.Page 32 of 40 05/03/22 1 A Because I wasn't told any different. 2 Q Do you know where any -- any source of …
…hobby, 3 really. 4 Q. Are you employed? 5 A. Nope. 6 Q. Do you have any source of 7 income? 8 A. My partner -- 9 MR. GUIRGUIS: I'm going to 10 object to that. Income is out. 11 …
…hobby, 3 really. 4 Q. Are you employed? 5 A. Nope. 6 Q. Do you have any source of 7 income? 8 A. My partner -- 9 MR. GUIRGUIS: I'm going to 10 object to that. Income is out. 11 …
…TGP highlights that it is addressing this gap as a trusted news source for the stories and views that are largely untold or ignored by traditional news outlets.5 One of its core values is that it “must have courage…
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