…R. Civ. P., and states as follows. I. BACKGROUND After receiving written briefs on the Plaintiff’s Motion for Forensic Examination (DE 96), and hearing oral argument on the same on May 12, 2016, this Court on June 20, 2016…
…providers or records because suing for $30 million of medical and Objections to First “privileged” mental injury Discovery Requests April 4 Plaintiff “has sent written Plaintiff had sent only one release to Plaintiff’s Response to …
…Plaintiff’s counsel and Defendant’s counsel have conferred about the Court’s proposed Protocol. Plaintiff agrees to the Court’s Protocol as written, including the Court’s proposal to review documents by Non-Party in the order that the…
…R. Civ. P., and states as follows. I. BACKGROUND After receiving written briefs on the Plaintiff’s Motion for Forensic Examination (DE 96), and hearing oral argument on the same on May 12, 2016, this Court on June 20, 2016…
…and correct copies of conferral communication between counsel, including a true and correct copy of Jeffrey Epstein’s written waiver of claims concerning settlement agreement’s confidentiality provision dated August 16, 2016. 4. Attached as Exhibit C (filed under seal…
…If you need assistance locating those release forms, please let me know. Also please consider this a written conferral. If you do not intend to gather and 3 https://www.humanservices.gov.au/sites/default/files/ms040-1607en.pdf 4…
…I think were running a piece written by Professor Dershowitz on Monday. If Miss Maxwell wants to make a comment do let me know ... All the best David Brown Reporter The Times "Please consider the environment before printing this e…
…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…
…defamation case and words are important in 22 this case. 23 THE COURT: That's true. 24 MR. PAGLIUCA: Those words written down by a plaintiff 25 prior to filing the litigation, some 300 pages of words, SOUTHERN DISTRICT REPORTERS…
…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…
…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…
…announcements, and sound recordings of any nature. “Document” also means all copies which are not identical to the original document as originally written, typed or otherwise prepared. The term “Document” shall also include all documents of any nature that have…
…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…
…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…
…on any day thereafter. 5. Adjournments of the dates set forth above will not be granted except for good cause and upon written application made as soon as the grounds for such application are known. 6. Failure to comply with…
…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…
…that the newest iteration of her story contained in the I CVRA litigation differed materially from her rior "memories" which were written wli'en she was riot planninglitigation and rlbt motivate
…a 2003 Vanity Fair article, written before the Jeffrey Epstein scandal broke, describes Maxwell as someone who “seems to organize much of [Epstein’s] life -- recently she was making telephone inquiries to find a California-based yoga instructor for him…
…40 a. the date of any such Communication; b. the form of any such Communication, whether oral or written and if written, the format of any such Communication; c. the identities of all persons involved in the Communication, including the…
…the same freely and vo/untarif;· for the uses and purposes therein mentioned. [SEAL] offtera/ seal the d.iy and year 1asl above written. Hsiao-Chi…
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