…asseur, ” “ therapy” etc.asyou requested, butyou w ould stilllikem etosearchasubsetof124-341 surnam esnam esforallcom m unicationsw ithcertain w itnessesthatyou believerelateto“ m assages.” IsaidIw ould lookatyourlist,w henyou send it,and evalu…
…asseur, ” “ therapy” etc.asyou requested, butyou w ould stilllikem etosearchasubsetof124-341 surnam esnam esforallcom m unicationsw ithcertain w itnessesthatyou believerelateto“ m assages.” IsaidIw ould lookatyourlist,w henyou send it,and evalu…
…relate to your RFP number 5 (“All documents relating to massages…”). I represented to you that I have searched for the terms “massage,” “masseur,” “therapy” etc. as you requested, 1 Case 1:15-cv-07433-LAP Document 1327…
…believethatsearchterm s124-341,w hicharew itnessnam esbrokenupintofirstand last nam esfrom yourR ule26 list,relatetoyourR FP num ber5 (“ Alldocum entsrelatingtom assages… ” ).I represented toyou thatIhavesearchedfortheterm s“ m assage, ” “ m asseur, ” “…
…relate to your RFP number 5 (“All documents relating to massages…”). I represented to you that I have searched for the terms “massage,” “masseur,” “therapy” etc. as you requested, but you would still like me to search a subset…
…believethatsearchterm s124-341,w hicharew itnessnam esbrokenupintofirstand last nam esfrom yourR ule26 list,relatetoyourR FP num ber5 (“ Alldocum entsrelatingtom assages… ” ).I represented toyou thatIhavesearchedfortheterm s“ m assage, ” “ m asseur, ” “…
…nde r stand what 20 you and your lawyer have said here t oday , yo u have 21 been i nvolved in some n umber of years of therapy , i n 22 which the purpose -- part o f t he…
…Maxwell already had run the Plaintiff’s proposed terms related to massages, including “massage,” “masseuse,” “masseur,” and “therapy.” In effect, Plaintiff proposed search terms sought to expand her discovery requests from communications with a discrete set of individuals to all…
…emotional problems, psychological or psychiatric disorders, sexually transmitted diseases, and therapy records, and any prescriptions for any of the above categories. 25. Any Documents containing any Communications You have had with any law enforcement agency. 26. Any Documents that reflect…
…psychological or psychiatric disorders, sexually transmitted diseases, and therapy records, and any prescriptions for any of the above categories. RESPONSE: In addition to the Preliminary Statement and General Objections, Ransome objects to this request in that she is a non…
…of confidentiality under the Protective Order. During the deposition, this Doe testified that she had undergone extensive therapy to overcome the trauma and did not want to be involved in the proceedings at all. The Second Circuit sua sponte redacted…
…psychological or psychiatric disorders, sexually transmitted diseases, and therapy records, and any prescriptions for any of the above categories. RESPONSE: In addition to the Preliminary Statement and General Objections, Ransome objects to this request in that she is a non…
…emergency care or other treatment for any eating disorder, malnourishment, kidney malfunction, emotional problems, psychological or psychiatric disorders, sexually transmitted diseases, and therapy records, and any prescriptions for any of the above categories. (Complaint ¶ 52, 64; motivation to fabricate) 25…
…doctor, nurse, psychiatrist, psychologist, counselor, therapist, social worker, or other medical or mental health care practitioner, and includes any Person or entity referred to as a “Health Care Professional” or “Health Care Institution” in Colorado Revised Statute § 13-64-202…
…Court is aware, this defamation case involves Ms. Giuffre's assertions that she and other females were recruited by Defendant to be sexually abused by Jeffrey Epstein under the guise of being "massage therapists." See Complaint, (DE 1). at~ 27…
…the Court is aware, this defamation case involves Ms. Giuffre’s assertions that she and other females were recruited by Defendant to be sexually abused by Jeffrey Epstein under the guise of being “massage therapists.” See Complaint, (DE 1), at …
…psychological or psychiatric disorders, sexually transmitted diseases, and therapy records, and any prescriptions for any of the above categories. RESPONSE: In addition to the Preliminary Statement and General Objections, Ransome objects to this request in that she is a non…
…Court is aware, this defamation case involves Ms. Giuffre's assertions that she and other females were recruited by Defendant to be sexually abused by Jeffrey Epstein under the guise of being "massage therapists." See Complaint, (DE 1). at 127…
…has little or no memory of most or all of the events surrounding the time she knew Mr. Epstein, and specifically testified that she is in therapy for the purpose of repressing any memories concerning Mr. Epstein. See Menninger Decl…
…asseur, ” “ therapy” etc.asyou requested, butyou w ould stilllikem etosearchasubsetof124-341 surnam esnam esforallcom m unicationsw ithcertain w itnessesthatyou believerelateto“ m assages.” IsaidIw ould lookatyourlist,w henyou send it,and evalu…
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