DataSet-9
EFTA01078765
90 pg
…and Defendant's threats and intimidation, it would be both
unreasonable and oppressive to require this non-party to comply with this subpoena duces tecum.
Accordingly, Defendant's subpoena should be quashed. See Exhibit 6, Defendant's Subpoena to
Jane…
DataSet-9
EFTA01078855
90 pg
…and Defendant's threats and intimidation, it would be both
unreasonable and oppressive to require this non-party to comply with this subpoena duces tecum.
Accordingly, Defendant's subpoena should be quashed. See Exhibit 6, Defendant's Subpoena to
Jane…
DataSet-10
EFTA01728788
22 pg
…Black that would not have to appear and produce
the disputed items if a motion to quash all aspects of the subpoenas was filed. Neither party's
pleading has asserted that the subpoenas should be quashed as to testimony. Thus…
DataSet-9
EFTA00069870
26 pg
…that Mr. Epstein's Aug. 10 death was a suicide by hanging.
Still, that has not quashed unfounded conspiracy theories that claim other people may have played a role in
silencing Mr. Epstein, whose social circle included celebrities, academics and…
DataSet-9
EFTA00590248
38 pg
…that the documents requested are not related to any pending claim or
defense").
BSF contends that the subpoena should be quashed because Dershowitz is seeking
information that is relevant to the Federal Action and is wholly unconnected to this suit…
DataSet-9
EFTA01078617
148 pg
…obtain documents. The District Court quashed the subpoenas for the law firm's records
finding among other things that the requests were overly broad and included requests for
documents irrelevant to the claims at issue in the underlying action. Id…
DataSet-9
EFTA00728009
24 pg
…Rush's journalistic endeavors. (Point III.) The subpoenas
should therefore be quashed in their entirety or a Protective Order issued to prevent their
enforcement.
ARGUMENT
POINT I: WHETHER ANALYZED UNDER THE REPORTER'S PRIVILEGE OR THE
FEDERAL RULES, HAS NOT…
DataSet-9
EFTA00077361
5 pg
…key details of their stories, including visit to
the New York police and her referral to the F.B.I.
But though the investigation progressed, a widely criticized plea deal eventually quashed any federal
prosecution. To , the 2008 plea agreement…
DataSet-10
EFTA01656051
15 pg
…2016 presidential campaign, as well as
https://sendy.barbaricum.cornAW5g2b692W1JFSAIhRy8922GWsVA/D7h892P8xUD9RG692Sk892pRgyGAibjb2r1R9BuhO3YTw3zYXVA 9/15
EFTA01656059
9/4/24. 6:42 AM …
DataSet-9
EFTA01079203
60 pg
…and Defendant's threats and intimidation, it would be both
unreasonable and oppressive to require this non-party to comply with this subpoena duces tecum.
Accordingly, Defendant's subpoena should be quashed. See Exhibit 6, Defendant's Subpoena to
Jane…
DataSet-9
EFTA00092968
8 pg
…of their stories,
including visit to the New York police and her referral to the F.B.I.
EFTA00092974
But though the investigation progressed, a widel criticized plea deal
eventually quashed any federal prosecution. To …
DataSet-9
EFTA00612027
38 pg
…CORPORATION
Headnotes
NEWSGATHERING
[1] Forced disclosure of information — Disclosure of unpublished information — In civil actions (.60.1003)
Forced disclosure of information — Common law privilege (.60.20)
Plaintiff's subpoena seeking documents and testimony from nonparty media entity will be quashed…
DataSet-9
EFTA01206865
38 pg
…that the documents requested are not related to any pending claim or
defense").
BSF contends that the subpoena should be quashed because Dershowitz is seeking
information that is relevant to the Federal Action and is wholly unconnected to this suit…
DataSet-9
EFTA00094959
8 pg
…and , outlining key details of their stories,
including visit to the New York police and her referral to the F.B.I.
But though the investigation progressed, a widely criticized plea deal
eventually quashed any federal prosecution. To the sisters…
DataSet-9
EFTA00207332
24 pg
…s journalistic endeavors. (Point III.) The subpoenas
should therefore be quashed in their entirety or a Protective Order issued to prevent their
enforcement.
ARGUMENT
POINT I: WHETHER ANALYZED UNDER THE REPORTER'S PRIVILEGE OR THE
FEDERAL RULES, DOE HAS NOT…
DataSet-9
EFTA00207294
38 pg
…CORPORATION
Headnotes
NEWSGATHERING
[1] Forced disclosure of information — Disclosure of unpublished information — In civil actions (.60.1003)
Forced disclosure of information — Common law privilege (.60.20)
Plaintiff's subpoena seeking documents and testimony from nonparty media entity will be quashed…
DataSet-9
EFTA01250614
38 pg
…NEWSGATHERING
[1] Forced disclosure of information — Disclosure of unpublished information — In civil actions (a 60.1003)
Forced disdosure of information — Common law privilege (a 60.20)
Plaintiff's subpoena seeking documents and testimony from nonparty media entity will be quashed…
giuffre-maxwell
gov.uscourts.nysd.447706.363.6
15 pg
…and Defendant’s threats and intimidation, it would be both
unreasonable and oppressive to require this non-party to comply with this subpoena duces tecum.
Accordingly, Defendant’s subpoena should be quashed. See Exhibit 6, Defendant’s Subpoena to
Jane…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…Remarkably, Dershowitz fails to note that same documents he seeks
here (to use in the next installment of his media campaign) are the exact type of documents that
Judge Lynch quashed from Dershowitz’s subpoena he served on Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.31
13 pg
…Const. amend. IV.
9
Case 1:15-cv-07433-LAP Document 1328-31 Filed 01/05/24 Page 11 of 13
about privacy. (This Court quashed those subpoenas, see June 23, 2016, Minute Entry).
Defendant cannot argue to the…
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