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7# Jane Doe Vs Epstein 2018 PDF
7# Jane Doe Vs Epstein 2018 PDF
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Speakerphone Conference
1 UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
2 ------------------------------x
5 v. 17 Civ. 0616(JGK)
7 Defendants.
8 ------------------------------x
9 November 7, 2018
4:00 p.m.
10
Before:
11
HON. SARAH NETBURN,
12
Magistrate Judge
13
APPEARANCES (via speakerphone)
14
BOIES, SCHILLER & FLEXNER LLP
15 Attorneys for Plaintiff
BY: SIGRID S. McCAWLEY
16 - and -
PAUL G. CASSELL
17 Attorney for Plaintiff
24
25
3 have you here with my law clerk and with a court reporter.
12 another and do your very best not to speak over somebody who is
13 speaking.
16 from a nonparty.
24 electronic copies?
16 whether or not the designating party had a good faith basis and
14 paragraph.
20 confidential that may not have -- they may not have a good
9 However, unlike prior cases that we have had that have dealt
10 with minors, the plaintiff in this case was not a minor at the
16 here? What are you worried about producing that you want to
17 keep confidential?
22 claims also that she was directed by my client and the Epstein
17 raise that concern, and then if the parties still can't agree,
23 order.
9 for both paragraphs, both paragraph 3's, that when the dispute
22 (Pause)
24 the plaintiff.
12 seal, in my view.
21 be passed along to the New York Times. And so, you know, it
2 the public.
3 Is there a way that you think you can narrow the issue
11 discovery requests thus far and see if there are any additional
8 completely wrong and they don't plan to ask those same kind of
24 happy to do that.
3 Sorry.
4 (Pause)
11 protect.
12 OK. Paragraph 8.
16 the obligation and the right to do so, but maybe in this case
17 there are other concerns that I am not focusing on. Who wants
2 provide --
4 half as fast.
14 confidential information.
2 designation?
7 them that they did not want marked as confidential, under the
20 (Pause)
25 everyone.
2 be heard on this --
13 It's one thing to say that the defendant -- you know, that
19 you said.
25 goes too far in the designation, then we'll be back before you,
2 the attorney's fees and costs and enforce the protective order
7 again.
20 is necessary.
25 invoke to keep from the press his or her sexual activity? That
3 the comment made by Mr. Link, which is that, you know, someone
2 if they so choose.
6 Let's --
9 misstatement.
22 are connected.
25 the plaintiff.
23 in any manner, you would have to track down every single email
25 destroyed it.
13 say that absent a court order, you know, that the party is not
17 can tell the party that subpoenas you, sorry, I'm bound by a
24 litigation is over.
6 Ms. Maxwell.
8 is just to make sure we all are clear about what a court order
6 maybe better crafted which said you make a good faith effort to
13 media.
19 this. What do you think about this? Etc. Etc. And to comply
21 need to then, you know, cull through their emails almost like
2 that is cutting out, but I'm only hearing a few words here and
5 Laura Menninger.
9 (Pause)
15 hear better.
17 pretty close.
7 you all have experience to know that that conduct may arise,
8 but the parties are going to sign this protective order and
12 not sure that any wordsmithing that we're going to do here with
14 be that much more powerful than the fact that I will hold the
16 protective order.
24 competent jurisdiction.
15 about Ms. Giuffre's case and has introduced Ms. Giuffre. And
3 the plaintiff.
14 not make any comment that Laura had just stated that he did.
17 can account for all of the potential scenarios that the parties
7 order is entered.
13 deposition tomorrow.
24 Menninger.
2 you as well.
4 (Adjourned)
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