e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic

l be correct, that Dcrshowitz was always free to sue if he felt aggrieved by what he views as her false and defamatory statements about him. But the Federal Rules of Civil Procedure require Dershowitz, at the motion to dismiss stage, to satisfy different requirements from those applied to Plaintiff. The putative "unf

92. We lack jurisdiction to hear this appeal under § 1291 because the district court's August 17, 1995 order is not a final judgment. Rule 54(b) of the Federal Rules of Civil Procedure sets forth the requirements for the entry of a partial final judgment in multi-claim or multi- party actions. [FIN1] Under Rule 54(b), an

rs. III. PETITIONERS HAVE NO RIGHT TO DISCOVERY UNDER THE FEDERAL RULES OF CIVIL PROCEDURE Petitioners argue they are entitled to discovery under the Federal Rules of Civil Procedure, but they point to no particular rule, or case, which provides that such a discovery rights exists. Instead, petitioners seize upon the g

e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic

ell). Id. The Court then noted: "Because the Court will allow this limited factual development, it is unnecessary to decide here whether the CVRA or the Federal Rules of Civil Procedure provide discovery rights in this context. The Court therefore reserves ruling on [the victims'] motion [for an order directing the Govern

ly to this case. D.E. 99 at 11 ("Because the Court will allow this limited factual development, it is unnecessary to decide here whether the CVRA or the Federal Rules of Civil Procedure provide discovery rights in this context."). Petitioners cannot obtain initial disclosures under Rule 26(a)(1) by simply incorporating it

26(a)(1). Although Petitioners have already served their Rule 26(a)(1) disclosures (DE 266 at 13), and although this Court has repeatedly held that the Federal Rules of Civil Procedure "govern the general course of this proceeding," the Government maintains that the rule governing initial disclosures in civil litigation d

orcement proceeding because it is not a "civil action" against the Government. To be sure, this Court has determined that convenience dictates that the Federal Rules of Civil Procedure "govern the general course of this proceeding." See DE 257 at 3. But that procedural determination does not alter the substance of this ca

umscribe that discretion. Where discovery materials are concerned, the constitutional right of access standard is identical to that of Rule 26(c) of the Federal Rules of Civil Procedure." Chicago Tribune, 263 F.3d at 1310. Accordingly, "where a third party seeks access to material disclosed during discovery and covered by

we are also writing to ask for your non-opposition to Jane Doe No. 3 and Jane Doe No. 4's motion to intervene in the case. As you know, Rule 24 of the Federal Rules of Civil Procedure allows intervention on two grounds: Mandatory intervention is allowed where a putative intervenor "claims an inter relating to the . . .

ely confidential or cloaked with a qualified immunity," and must, therefore, "balance the countervailing policies of liberal discovery set forth in the Federal Rules of Civil procedure against maintaining the confidentiality of such documents." W. To achieve that balance, courts in the Second Circuit have developed a "mo

URE STATEMENT Defendant by and through her attorneys, Steptoe & Johnson LLP, hereby submits her Initial Disclosures pursuant to Rule 26(aXI)(A) of the Federal Rules of Civil Procedure based upon information currently known or available. PRELIMINARY STATEMENT =joys the protections of the self-incrimination clause of th

STATEMENT Defendant by and through her attorneys, Steptoe & Johnson LLP, hereby submits her Initial Disclosures pursuant to Rule 26(a)( I )(A) of the Federal Rules of Civil Procedure based upon information currently known or available. PRELIMINARY STATEMENT =njoys the protections of the self-incrimination clause of t

ely confidential or cloaked with a qualified immunity," and must, therefore, "balance the countervailing policies of liberal discovery set forth in the Federal Rules of Civil procedure against maintaining the confidentiality of such documents." Id. To achieve that balance, courts in the Second Circuit have developed a "m

E MAXWELL, and Defendants. PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN PLEASE TAKE NOTICE THAT, pursuant to Rule 30 of the Federal Rules of Civil Procedure, counsel for Plaintiff, will take a videotaped deposition of the Defendant as set forth below: NAME: Jeffrey Epstein DATE AND TIME:

MAXWELL, and Defendants. PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION OF GHISLAINE MAXWELL PLEASE TAKE NOTICE THAT, pursuant to Rule 30 of the Federal Rules of Civil Procedure, counsel for Plaintiff, will take a videotaped deposition of the Defendant as set forth below: NAME: Ghislaine Maxwell DATE AND TIME:

17 Civ. 00616 (JGK) XWELL, and Defendants. PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION F PLEASE TAKE NOTICE THAT, pursuant to Rule 30 of the Federal Rules of Civil Procedure, counsel for Plaintiff, will take a videotaped deposition of the Defendant as set forth below: NAME: DATE AND TIME: August 24, 2018 a

fraud or coercion against any of the defendants; third, the amended complaint impermissibly lumps the defendants together in violation of Rule 8 of the Federal Rules of Civil Procedure; and, fourth, the amended complaint fails to demonstrate that the alleged fraudulent or coercive conduct caused the plaintiff to engage

. Ghislaine Maxwell, Defendant. NOTICE OF SERVICE OF RULE 45 SUBPOENA UPON SHOPPER'S TRAVEL, INC. PLEASE TAKE NOTICE THAT, pursuant to Rule 45 of the Federal Rules of Civil Procedure, Plaintiff, hereby provides Notice of Service of Subpoena upon Shopper's Travel, Inc. A copy of the Subpoena is attached to this Notice.