Defendant’s Combined Response to Plaintiff’s Motion to Compel Defendant to Answer Deposition Questions Filed Under Seal and
Motion to Terminate or Limit Pursuant to F.R.Civ.P. 30(d)(3) drive.google.com/file/d/1am1anS…
PLAINTIFF’S UNREDACTED REPLY IN SUPPORT OF MOTION TO COMPEL DEFENDANT TO ANSWER DEPOSITION QUESTIONS
PLAINTIFF’S NON-REDACTED MOTION TO EXCEED PRESUMPTIVE TEN
DEPOSITION LIMIT IN FEDERAL RULE CIVIL PROCEDURE 30(A)(2)(a)(ii) drive.google.com/file/d/1am1anS…
RESPONSE TO MOTION TO COMPEL ATTORNEY-CLIENT COMMUNICATIONS
AND ATTORNEY WORK PRODUCT MATERIALS
April 13, 2014, Ukrainian energy company Burisma announces the hiring of Hunter Biden business partner Devon Archer who also served as a senior advisor to Secretary-of-State John Kerry. Archer was also the college roommate of CJ Heinz, Kerry’s stepson.bbc.com/news/blogs-ech…
ORDER: In light of the Court's order dated October 2, 2020, declining to construe an email to the Court from Does 1 and 2 as a formal objection to unsealing and giving Does 1 and 2 14 days after service of requested excerpts to file a formal objection
to unsealing (dkt. no. 1125), the transcript of Doe 1's deposition and materials quoting that transcript or disclosing information from that transcript shall not be unsealed tomorrow.
The Court received word from the parties that Does 1 and 2 would be served with the relevant excerpts today, after which Does 1 and 2 will have 14 days to lodge a formal objection to unsealing
Counsel for Maxwell, requests that the Court refuse to “confirm” Plaintiff’s proposed course of action citing Plaintiff’s proposal does not redact all “descriptions of nonparty conduct that would allow readers to discern the identity of a non-party.”
MEMO ENDORSEMENT filed by Virginia Giuffre
Counsel may proceed with filing the relevant documents to the public docket, subject to the previously-ordered redactions. SO ORDERED
ORDER: The Court received notice of the filing of Ms. Maxwell's letter of today after its order directing Ms. Giuffre to post the relevant materials had been docketed.
The direct involvement of Hunter Biden and Heinz in the acquisition of Henniges by the Chinese government creates a potential conflict of interest. Both are directly related to high- ranking Obama administration officials.