…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 …
…issues orally with Brad last week, I am including them in written form so that there can be no dispute about our position. I do object to the vast number of your 368 search terms. Most are not tied 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…
…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…
…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…
… If it helps, have your attorney write a suggested column- oriented item re your case and if it's written in 'journalistic style,' Colin and I can pop it off to Emily, as a possible piece f, her renowned Page…
…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…
…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…
…independent contractor or any other person acting, or purporting to act, at the discretion of or on behalf of another. 2. “Correspondence” or “communication” shall mean all written or verbal communications, by any and all methods, including without limitation, letters…
…independent contractor or any other person acting, or purporting to act, at the discretion of or on behalf of another. 2. “Correspondence” or “communication” shall mean all written or verbal communications, by any and all methods, including without limitation, letters…
…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…
…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…
…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.…
…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…
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