… One set of 10 them are a bunch of photographs. I have looked at them, 11 nothing prurient about them, they all predate the statute of 12 limitations time period and were used during the deposition. 13 THE COURT: Yes…
…4 A. She is being sued by Virginia Roberts for 5 defamation, not for the underlying offenses, which 6 are beyond the statute of limitations, as I 7 understand it, correct. 8 Q. And have you spoken with Ghislaine Maxwell…
…in order for of allegedly defamatory statement gave rise to defamation claim to survive motion to dismiss, new defamation claim against purported allegedly defamatory statement must contain at defamer, and thus statute of limitations did not least one false factual…
…DEFENSES 23. The Complaint fails to state a claim upon which relief could be granted. 24. Plaintiff’s claims may be barred by the statute of limitations. 25. Plaintiff’s claims are barred by the “single publication” rule. 26. Plaintiff…
…state. 7. Unless instructed otherwise, each Request shall be construed independently and not by reference to any other Request for the purpose of limitation. 8. The words “relate,” “relating,” “relates,” or any other derivative thereof, as used herein includes concerning…
…state. 7. Unless instructed otherwise, each Request shall be construed independently and not by reference to any other Request for the purpose of limitation. 8. The words "relate," "relating," "relates," or any other derivative thereof, as used herein includes concerning…
…7. Unless instructed otherwise, each Request shall be construed independently and not by reference to any other Request for the purpose of limitation. 8. The \vords "relate," "relating," "relates," or any other derivative thereot~ as used herein includes concerning, referring…
…state. 7. Unless instructed otherwise, each Request shall be construed independently and not by reference to any other Request for the purpose of limitation. 8. The words "relate," "relating," "relates," or any other derivative thereof, as used herein includes concerning…
…non-identical copy is a separate document within the meaning of this term. 5. “Employee” includes a past or present officer, director, agent or servant, including any attorney (associate or partner) or paralegal. 6. “Including” means including without limitations. 7…
…state. 6. Unless instructed otherwise, each Request shall be construed independently and not by reference to any other Request for the purpose of limitation. 7. The words “relate,” “relating,” “relates,” or any other derivative thereof, as used herein includes concerning…
…interests. Finally, like Mr. Dershowitz’s original Motion, the Government here seeks all deposition material and exhibits, sealed or unsealed, without any limitations on the scope of the needs of their case against Mr. Epstein’s estate. (Doc. # 1113, p…
…state. 7. Unless instructed otherwise, each Request shall be construed independently and not by reference to any other Request for the purpose of limitation. 8. The words “relate,” “relating,” “relates,” or any other derivative thereof, as used herein includes concerning…
…i ng with h er to t he deposition several broad categories of documents : l . All Documents containing communications with Virginia Roberts. 2. All communications with any age n t for Virginia Roberts , including withou t limitation attorneys Bradley Edwards…
…or alluded to in Your Complaint, or any that could be included in any amended complaint in this action. 7. “Employment” includes without limitation, the provision of work and/or services, whether paid or unpaid, whether as an employee, intern…
…investigation of the same, which have been previously produced, are available in the public domain, or referenced in court papers. Defendant also refers Plaintiff to documents within the possession, custody and control of Plaintiff and her counsel, including without limitation…
…Pfizer’s duty to preserve extended back to earlier, unrelated litigations). The Pfizer court further explained: “In addition, the duty to preserve only extends to documents relevant to the claim of which the party has notice.” In re Pfizer Inc…
…CONSTITUTIONALITY OF j ) 230 RENT LEASE & [ ] 44 5 AMERICANS WITH [ I 555 PRISON CONDITION [ I 465 OTHER IMMIGRATION STATE STATUTES EJ ECTMENT DISABILITIES - [ ] 550 CIVI L DETAINEE AC TI ONS [ 1240 TORT…
…071.These statutes apply to GM_00785-801 and GM_00775, the police reports regarding the sexual battery committed against Ms. Giuffre when she was fourteen years old. Furthermore, Section 794.026, Fla. Stat., creates a civil right of action…
…Sys., Inc., 752 F.2d 16 (2d Cir. 1984) .................................................................................................. 10, 11 4 Case 1:15-cv-07433-LAP Document 1259 Filed 07/28/22 Page 5 of 17 STATUTES 18 U.S.C. § 2 .…
…The conduct explicitly described by statute as privileged does not operate as waiver, and again Defendant has provided no factual basis to suggest Plaintiff has misrepresented the identity or role of the third-parties listed . Defendant's request is denied…
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