…OBJECTIONS TO UNSEALING Case 1:15-cv-07433-LAP Document 1247 Filed 03/18/22 Page 2 of 25 TABLE OF CONTENTS PRELIMINARY STATEMENT .................................................................................................1 ARGUMENT ..............................................…
…unwarranted and prejudicial pretrial publicity by the Government, its agents, and lawyers for alleged witnesses. Legal Standard More than fifty years ago, warning of the danger of pretrial publicity to fair trials, the Supreme Court directed trial judges to take…
…P. 24(a). Nor has he met Rule 24(b)’s standards for discretionary intervention for four reasons: First, Dershowitz has another forum in which to litigate and defend his reputational interests – a pending defamation action regarding this very case…
… 8 Q. And what kind of system was that? 9 Q. Was he there everyday? 9 A. It was standard office equipment, Lucid 10 A. No, ma'am. 10 Technologies maybe, but it was an intercom like we 11 Q…
…the witnesses to appear via a trial subpoena. Accordingly, Ms. Giuffre seeks leave to take more than the standard ten depositions in this case. At this time, she seeks leave to take seven additional depositions, as articulated below.2 2…
…the witnesses to appear via a trial subpoena. Accordingly, Ms. Giuffre seeks leave to take more than the standard ten depositions in this case. At this time, she seeks leave to take seven additional depositions, as articulated below.2 2…
…who is 22 admittedly located in London. 23 Finally, your Honor, there is a lot of confusion 24 contained in the paperwork with regard to the standard of 25 malice that must be pled. Again your Honor has found, and …
…it would become standard operating procedure, 19 and the resulting wholesale exposure of press files to 20 litigants' scrutiny would burden the press with heavy costs of 21 subpoena compliance and could otherwise impair its ability to 22 perform its…
…is 22 admittedly located in London. 23 Finally, your Honor, there is a lot of confusion 24 contained in the paperwork with regard to the standard of 25 malice that must be pled . Again your Honor has found, and SOUTHERN…
…the witnesses to appear via a trial subpoena. Accordingly, Ms. Giuffre seeks leave to take more than the standard ten depositions in this case. At this time, she seeks leave to take seven additional depositions, as articulated below.2 2…
…that “[c]ourts would undermine the purpose of the reporter’s privilege and severely curtail its applicability if the standard hinged on whether the reporter had previously researched the subject of the subpoena for a high school or college paper…
…$15 million in assets appears even more alarming. And, evidence of consciousness of guilt is admissible in criminal cases, even where the standard of proof is much higher than in a civil case. See, e.g., United States v. Amuso…
…Giuffre’s defamation claim. If that were the standard, then discovery in every civil case would be stayed at the commencement of the action until the court ruled on the motion to dismiss because virtually all defendants in civil cases…
…the witnesses to appear via a trial subpoena. Accordingly, Ms. Giuffre seeks leave to take more than the standard ten depositions in this case. At this time, she seeks leave to take seven additional depositions, as articulated below.2 2…
…that “[c]ourts would undermine the purpose of the reporter’s privilege and severely curtail its applicability if the standard hinged on whether the reporter had previously researched the subject of the subpoena for a high school or college paper…
…the witnesses to appear via a trial subpoena. Accordingly, Ms. Giuffre seeks leave to take more than the standard ten depositions in this case. At this time, she seeks leave to take seven additional depositions, as articulated below.2 2…
…Y. 2011) (denying sanctions). Indeed, “relevance requires a showing beyond 3 The Pfizer Court applies a negligence standard which is applicable to the documents at issue here, should this Court find that any duty attaches, which it does not, as…
…L.(E.)) [1980] in their possession, custody or power the documents " relating to the . matters in question in this action" enumerated in the first schedule, is standard form. Marr-Johnson following on the Commonwealth authorities. As to Grant v. Downs…
…Doe 171 requires this Court’s clarification regarding the Court’s standards and procedures for maintaining the confidentiality of ex parte submissions for purposes of explaining the basis of her concerns and providing a supporting declaration. Our initial investigation indicated…
…perfect sure. 5 Q. When you were sexually trafficked to the 6 prince were you underage? 7 A. Not by England's standards. 8 Q. You weren't in England, were you, you were 9 in the South of France…
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