4
Shared Docs
4
Same-Page
5 / 4
Mentions
3, 2014) (internal quotation marks omitted)). Moreover, at least one New York court has found that British privilege law is "apparently similar" to New York's. Aetna Cas. & Sur. Co. v. Certain Underwriters at Lloyd's London, 4 "Where there is no attorney involved in the communication ..., there can be no
uffre v. Maxwell, No. 15 CIV. 7433 (RWS), 2016 WL 831949, at *2 n.2 (S.D.N.Y. Feb. 29, 2016) ("Because New York has the most significant interest, New York law applies."). The potential litigation for which Defendant sought Barden's advice never came to frOition and no • pending issues in or relating
l defense interest, which cloaks related communications in privilege, and a common problem, to which the privilege does not apply. Cgiazaryan, 290 F.R.D. at 434 (citing Finkeiman v. Klaus, 2007 WL 4303538, at *4 (N.Y.Sup.Ct. Nov. 28, 2007)). "IA] limited common purpose (that) necessitates disclosure"
or modify the subpoena . .. or to seek permissive intervention in the private action.") (internal quotations omitted); but see Palmieri v. State of N. Y., 779 F.2d 861, 862 (2d Cir. 1985) (considering appeal where the New York State Attorney General, rather than the subject of the subpoena, was the m
is more difficult to show a party reasonably relied on a blanket order in producing documents or submitting to a deposition." Id (quoting EPDM, 255 F.R.D. at 319). The second factor—the language of the Protective Order itself—similarly weighs in favor of modification. The Protective Order provided tha
8 U.S.C. § 2423(b). Jane Does #1 through #19 were all minors at the time of their involvement with defendant Epstein. Jane Doe #11 was a resident of New York; the remaining Jane Does were all residents of Palm Beach County, Florida, at the time of their involvement with defendant Epstein. Count 1 carries
vernment is required to demonstrate that there are grounds for a hearing under the specific provisions of either 3142(f)(1) or (f)(2)." Butler, 165 F.R.D. at 71. "When there exists one or more grounds for holding a hearing under those provisions, the government may proceed on the theory of risk of fli
rman ("Sherman"), Hoffenberg's uncle, vice-president. At DCC, Sherman had blank checks available for Hof- fenberg and put up the money to start Her New York and had made payments on Hoffenberg's apartment and boat mortgage. Stratford started op- erations in late December 1993 by taking on a few collecti
ere, preventing Epstein from identifying Plaintiffs' in subpoenas and other type discovery overwhelmingly inhibits discovery. Ees Doe v. Evans, 202 F.R.D. at 176 (E.D. P.A. 2001) (denying protective order where alleged sexual assault victim did not demonstrate a serious specific injury and allowing De
Entities connected to both New York and F.R.D.

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSON
Donald Trump
PERSONthe Southern District
LOCATION
George W. Bush
PERSONLeon Black
PERSON
Virginia Giuffre
PERSON
Julie K. Brown
PERSON
Alan Dershowitz
PERSON
Marc Rich
PERSONDarren Indyke
PERSONFBI
ORGANIZATION
Prince Charles
PERSON
U.S. Virgin Islands
LOCATION
Samantha Power
PERSON
George Mitchell
PERSON
Bradley Edwards
PERSON
Michael Jackson
PERSON