…has already asserted objections on her own behalf to many of the documents that will be at issue. In any event, Plaintiff is willing to confer with Maxwell in good faith to address ways to alleviate her burden. For example…
…of public record. We respectfully submit that plaintiff Ms. Giuffre and her counsel should not be permitted to abuse the Court’s willingness to accommodate the parties’ need to protect truly confidential materials in this way. Moreover, these improper redactions…
…to be opened up. Yes, there might be redactions, and my 5 client is willing to cooperate in all regards to that. We do 6 this all the time. I do other public records and judicial 7 records access. But…
…fact that “the names of the minor victims were already in the public record, and the record indicates that the victims may have been willing to testify despite the presence of the press,” would presumably have weighed against closure. Id…
…privilege applies. The discussion above relating to Objection 6 applies here. None of Plaintiff’s illegal sex activities, whether she was a willing participant or a victim, is cloaked with any privilege. Plaintiff’s deficient answer. Plaintiff suggested …
…x Dr. Karen Kutikoff x Wellington Imaging Associates x Growing Together. 1 That motion remains open. 3 Case 1:15-cv-07433-LAP Document 1320-33 Filed 01/03/24 Page 7 of 24 For some providers, Plaintiff provided…
…Karen Kutikoff Wellington Imaging Associates Growing Together. 1 That motion remains open. 3 Case 1:15-cv-07433-LAP Document 1198-1 Filed 01/27/21 Page 7 of 24 Case 1:15-cv-07433-LAP Document…
…x Dr. Karen Kutikoff x Wellington Imaging Associates x Growing Together. 1 That motion remains open. 3 Case 1:15-cv-07433-LAP Document 1320-33 Filed 01/03/24 Page 7 of 24 For some providers, Plaintiff provided…