gov.uscourts.nysd.447706.66.0_1.pdf PDF
…DISTRICT REPORTERS, P.C. (212) 805-0300 Case 1:15-cv-07433-LAP Document 66 Filed 03/23/16 Page 3 of 35 3 G3hdgium 1 written and we know that both sides know what it is, and that…
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gov.uscourts.nysd.447706.1219.42.pdf PDF
…12 Q. What did you put in the bonfire? 13 A. Any kind of memories that I had written 14 down about all the stuff going on. 15 Q. Had you written anything about Professor 16 Dershowitz? 17 A. He…
gov.uscourts.nysd.447706.1332.15.pdf PDF
…object to the confidentiality designations: “A party may object to the designation of particular CONFIDENTIAL INFORMATION by giving written notice to the party designating the disputed information… it shall be the obligation of the party designating the information as…
gov.uscourts.nysd.447706.89.0.pdf PDF
…legal team. Since returning to full time law teaching in 2007, Professor Cassell has developed a specialized expertise in crime victims’ rights, an area in which he has co-written a leading law school casebook. See Beloof, Cassell & Twist, Victims…
gov.uscourts.nysd.447706.1218.39.pdf PDF
…DISTRICT REPORTERS, P.C. (212) 805-0300 Case 1:15-cv-07433-LAP Document 1218-39 Filed 07/15/21 Page 4 of 36 3 G3hdgium 1 written and we know that both sides know what it is, and…
gov.uscourts.nysd.447706.39.1.pdf PDF
…1:15-cv-07433-RWS Document 39-1 Filed 03/02/16 Page 4 of 7 h. other persons by written agreement of the parties. 6. Prior to disclosing any CONFIDENTIAL INFORMATION to any person listed above (other than counsel…
gov.uscourts.nysd.447706.422.0.pdf PDF
…2016 Defendants responded to the Request for production stating “Ms. Giuffre is in possession of a document that contains a confidentiality provision. If Defendant obtains, and produces to Ms. Giuffre, a written waiver from . . . Mr. Epstein, of the confidentiality provision…
gov.uscourts.nysd.447706.958.3.pdf PDF
…thereto. As to 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…
gov.uscourts.nysd.447706.38.0.pdf PDF
…privacy interests. Plaintiff seeks to take the deposition of defendant Ghislaine Maxwell. Based on written discovery requests served to date, it is anticipated that Plaintiff will seek to question Ms. Maxwell concerning her personal and professional relationships as well matters…
gov.uscourts.nysd.447706.1182.0_1.pdf PDF
…judicial review or intervention. Specifically, Paragraph 11 of the Order permits “any party” to file Confidential Information in the public record so long as that party “obtain[s] written permission from the producing party to file such material.” Id. ¶ 11.…
gov.uscourts.nysd.447706.335.0.pdf PDF
…at ¶ 8. The Order continues: A party may object to the designation of particular CONFIDENTIAL INFORMATION by giving written notice to the party designating the disputed information. The written notice shall identify the information to which the objection is made…
gov.uscourts.nysd.447706.207.0.pdf PDF
…Giuffre has ever written or received that are maintained in her accounts, regardless of whether they were written to or from her attorney or to and from other personal friends or acquaintances who have nothing to do with this lawsuit…
gov.uscourts.nysd.447706.1106.0_2.pdf PDF
…including “deponents, witnesses, or potential witnesses” or “by written agreement of the parties.” Likewise, Paragraph 14 allows modification of the order by the Court “at any time for good cause.” Finally, Paragraph 13 provides that the Protective Order “shall have…
gov.uscourts.nysd.447706.1105.0.pdf PDF
…and affiants in the Maxwell case,” id. at 3 (emphasis added); and (2) “[a]ll documents produced, or deposition or written testimony given,” by a lengthy list of non-parties identified in an appendix, id. App. A (emphasis added)). Of…
gov.uscourts.nysd.447706.1325.19.pdf PDF
…Ms. Maxwell responds as follows: Ms. Maxwell already produced any written communications with Mr. Epstein that were responsive to the Interrogatory for the same, as limited by the Court to (a) all communications from January 2015 and (b) all documents…
gov.uscourts.nysd.447706.1201.20.pdf PDF
…case , incomparable to Defendant ' s med i a agent (and non - attorney) Ross Gow . That Pottinger has written non - legal material , or e ve n whether his " primary occupation in the most recent years [is] as a nove l ist…
gov.uscourts.nysd.447706.31.0_1_1.pdf PDF
…5 out the difference between slander and libel, and there is a 6 difference in the case law, as your Honor knows. 7 In the instance of libel, the written words, Cardozo 8 has said, it stings, it stings longer…
gov.uscourts.nysd.447706.1332.3.pdf PDF
…cross-examine attorney). To be sure, parts of Barden’s Declaration appear to have been cleverly written in an attempt obscure the fact that he is revealing attorney-client communications. But just as using the words “plan” and “intent” as…
gov.uscourts.nysd.447706.41.5.pdf PDF
…Material; and hi. any other persons by written agreement of the parties or by Order of a Court Formatted: Font: 12 pt of competent jurisdiction. 6. Prior to disclosing any CONFIDENTIAL INFORMATION to any person listed above (other than counsel…
gov.uscourts.nysd.447706.977.1.pdf PDF
…of perjury,” it is in fact exceedingly rare for anyone to be prosecuted for perjury in a civil proceeding.45 Similarly, 44 In relevant part, Rule 11 provides: By presenting to the court a pleading, written motion, or other paper . …
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