…disputes generally fall into two categories. The first is the manner by which confidential documents and testimony should be produced. We submit discovery should be conducted subject to a protective order. The second relates to the scope of discovery, and …
…21 and to witnesses who may be able to provide evidence of a wider, cross-border sex-trafficking ring. In connection with its ongoing investigation, the Miami Herald has sought to access public court filings that will shed light on…
…held that not only are motions for summary judgment dispositive, but even, “report[s] submitted in connection with a summary judgment motion [are] entitled to a strong presumption of access.” Bernstein, 814 F.3d at 142 (citing Joy v. North…
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