…Maxwell defendants, take no 14 position on our application. Judge Koeltl has expressed a 15 willingness to consider the information that we are seeking by 16 way of this modification. 17 THE COURT: Incidentally, as I understand it, what we…
…delay, Ms. Giuffre stated that she would be willing to “agree to a reasonable Protective Order being in place in this case” and attached a redlined version of Defendant’s proposed Protective Order. 1 See McCawley Decl. at Exhibit 4…
…protective order the parties supposedly “relied on” in making the productions. Yet, the Second Circuit ordered these materials released to the public (not just to another party willing to follow the protective order, as Dershowitz proposes here). In doing so…
…I certainly do feel that down the long, winding road, your case has merit! God willing that it puts that piece of human scurr back behind bars! Should you win the day, yes, T do believe that you can create…
…4, 2016, Plaintiff represented in Response that she “is willing to produce the Settlement Agreement and all documents concerning the Settlement Agreement if Defendant gets a waiver of liability from Jeffrey Epstein for its disclosure.” Doc. #78 at 15. Indeed…
…is whether the plaintiff would be willing to accept a form of sworn statement in response to questions whereby Epstein invokes his Fifth Amendment privilege in lieu of Epstein having to sit for a formal in-person deposition. 3 Case…
…July 13, 2016 8:22 PM To: Jeff Pagliuca Subject: Fwd: Your motions Jeff, Look I'm not going to be dragged into these nonsense emails. I'm willing to help clear up miscommunication if that indeed occurred. However, I…
…McCawley indicated on the record that she did not oppose an adjournment. In Plaintiff’s Reply, she indicated that she would be willing to make an additional attempt to confer before rescheduling the hearing on the Motion. Reply at 3…
…s decision to request a stay based solely on vague allusions to “critical new information” illustrates her disregard for the Court’s time, as well as her willingness to engage in dilatory conduct to thwart the unsealing process. See Dkt…
…any individual to whom CONFIDENTIAL information was shared pursuant to Paragraph 6 (and from whom there must be a written acknowledgment of their willingness to abide by the Protective Order): o The attorney who shared the CONFIDENTIAL information will obtain …
…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…
…Ms. Giuffre has been asking for April dates for this deposition since March. After repeated requests, counsel for Defendant was only willing to make Defendant available for deposition the first week of May, on the eve of trial. This motion…
…As indicated in her March 14 correspondence, Ms. Maxwell’s counsel is willing to discuss her ESI discovery protocols, but only if such discussion begins at a rational starting point for a single-plaintiff, single-defendant case such as this…
…because the people who want the testimony are willing to front the cost of the litigation either on a contingency or pro-bono basis. “Evidence tending to show a witness's bias or motive to fabricate testimony or evidence presented…
…flat refusal to discuss her ESI protocols (“ [w]e do not believe we have an obligation to describe for your [sic] our document search methods”), Defendant now acknowledges in her Response brief some willingness to do so.3 Yet, still…
…The letter states that these reports are subject to legal professional privilege but that Total is willing to waive privilege in these documents which were not prepared under the auspices of either the Total accident investigation team or the HOSL…
…Defendant’s response to Ms. Giuffre’s motion in limine on Esplin, Ms. Giuffre is willing to stipulate that she will rely on live testimony from Esplin instead of the designated deposition testimony. But because Esplin lives in Arizona, Ms…
…day. There has never been a shortage of lawyers suddenly seems to have a lot to say about a fleeting willing to represent people with claims against rich, incident she says happened with my client more than powerful men, so…
…2011) (holding that defendants 1 Ms. Giuffre’s counsel conferred with the Defendant but the Defendant was not willing to grant the request for an extension to complete the depositions requested by Ms. Giuffre. 5 Case 1:15-cv…
…because the people who want the testimony are willing to front the cost of the litigation either on a contingency or pro-bono basis. “Evidence tending to show a witness's bias or motive to fabricate testimony or evidence presented…
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