giuffre-maxwell
gov.uscourts.nysd.447706.57.2
30 pg
…between the defendants
and Powerhouse that privilege questions arise. In addition, the inquiry will consider
infringements relating to another transaction in relation to a concern identified as Apollo.
The defendants, or their group, did enter into a scheme with Apollo…
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…agreements, reports, objects, tangible things, work papers, transcripts, minutes,
reports and recordings of telephone or other conversations or communications, or of interviews
or conferences, or of other meetings, occurrences or transactions, affidavits, statements,
summaries, opinions, tests, experiments, analysis, evaluations, journals…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.29
24 pg
…agreements, reports, objects, tangible things, work papers, transcripts, minutes,
reports and recordings of telephone or other conversations or communications, or of interviews
or conferences, or of other meetings, occurrences or transactions, affidavits, statements,
summaries, opinions, tests, experiments, analysis, evaluations, journals…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…A. The USVI’s Motion to Intervene Should be Granted.
Federal Rule of Civil Procedure 24 provides for intervention as of right by anyone
claiming “an interest relating to the property or transaction that is the subject of the action…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…which evidence of the sale of property at fair market value to an
unrelated third party in an arms-length transaction of a house that was listed for sale prior to any
pending or threatened litigation could possibly be admitted…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.1
26 pg
…Q And how much would he pay you foreach girl
15 that you brought to him?
16 A Object form founds.
17 A Two hundred dollars apiece.
18 Q Where would this transaction tace place?
19 A Object to the…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…II. The Motion to Intervene is Granted
Federal Rule of Civil Procedure 24 provides
intervention of right under Rule 24(a) to anyone who "claims an
interest relating to the property or transaction that is the
subject of the action…
giuffre-maxwell
gov.uscourts.nysd.447706.509.0
18 pg
…key witnesses, editing
certain tapes before turning them over to defendant so that they would provide stronger evidence
in plaintiff's favor, and engaging in a sham transaction to unfairly bolster her claim); Miller v.
Time–Warner Commc'ns, No…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…allow a person to intervene in a case if that
person “claims an interest relating to the property or transaction that is the subject of that action
and is so situated that disposing of the action may as a practical…
giuffre-maxwell
gov.uscourts.nysd.447706.1349.0
31 pg
…. claims an interest relating to the property or transaction
that is the subject of the action.” (emphasis in original) (internal quotation
marks omitted)).
For reasons discussed in the preceding section, this means that the
intervention motion filings here at issue…
giuffre-maxwell
gov.uscourts.nysd.447706.555.0
21 pg
…witnesses, editing
I certain tapes before turning them over to defendant so that they would provide stronger evidence
in plaintiffs favor, and engaging in a sham transaction to unfairly bolster her claim); Miller v.
I Time- Warner Commc'ns, No…
giuffre-maxwell
gov.uscourts.nysd.447706.57.1
26 pg
…but (4) does not follow from (1) and (2). (1) is correct, but " relevant
facts" means the basic facts of the transaction, the res gestae, one
might almost say: the written documents in an accident case—typically,
the entry in…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…Swerdlow,
259 F.R.D. 64 (S.D.N.Y. 2009)..............................................................................................................26
In re Bank of New York Mellon Corp. Forex Transactions Litig.,
66 F. Supp. 3d 406 (S.D.N.Y. 2014).............................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.13
22 pg
…The Court explained that because the checks were “not confidential
communications but negotiable instruments to be used in commercial transactions,” and because
the bank statements contained information “exposed to [bank] employees in the ordinary course
of business,” Miller had only…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.27
11 pg
…100 (2d Cir. 1987); accord, e.g., In re Bank of New York Mellon Corp. Forex
Transactions Litig., 66 F. Supp. 3d 406, 410 (S.D.N.Y. 2014).
Plaintiff cites a bevy of cases from New York to Minnesota…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…Document 363-11 Filed 08/11/16 Page 7 of 40
FROM THE ABOVE THE LAW NETWORK
2016 Top Law Firm Gender Your Next Client Wants You Can’t Control Your
Transactional Law Firm Diversity Index to Hire You – NOW…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.28
24 pg
…agreements, reports, objects, tangible things, work papers, transcripts, minutes,
reports and recordings of telephone or other conversations or communications, or of interviews
or conferences, or of other meetings, occurrences or transactions, affidavits, statements,
summaries, opinions, tests, experiments, analysis, evaluations, journals…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…or of interview-s
Case 1:15-cv-07433-LAP Document 1320-31 Filed 01/03/24 Page 8 of 24
TO: .JEAN LUC BRU~EL
EXHIBIT A
or conferences, or of other meetings, occurrences or transactions, affidavits, statements,
summaries…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.32
27 pg
…or other conversations or communications, or of interviews
1
Case 1:15-cv-07433-LAP Document 1320-32 Filed 01/03/24 Page 9 of 27
or conferences, or of other meetings, occurrences or transactions, affidavits, statements,
summaries, opinions…
giuffre-maxwell
gov.uscourts.nysd.447706.223.1
14 pg
…agreements, reports, objects, tangible things, work papers, transcripts, minutes,
reports and recordings ofteJcphone or other conversations or communic.ations, or of interviews
or conferences, 01' of other meetings, occurrences or transactions, affidavits, statements,
sllmmaries, opinions, tests, experiments, analysis, evaluations, journals…
Comments