…Numerous depositions have already been taken by Ms. Giuffre without the benefit of these documents. The window for authenticating the documents through depositions 7 Case 1:15-cv-07433-LAP Document 1332-1 Filed 01/08/24 Page 9…
…make a convoluted legal argument, not to actually seek discoverable information. In light of this, the “burden or expense of the proposed discovery outweighs its likely benefit, considering the needs of the case, the parties' resources, the importance of the…
…for two hour on each subject, up to a total of four hours. The Defendant should not get a benefit from having twice improperly withheld information, by collapsing the two hours needed to address each of these topics into an…
…confidence in the administration of justice.”). Indeed, the motion to intervene is devoid of any citations to precedent that allows an individual to exploit these bedrock legal principles solely for his personal benefit, rather than the public at large. Furthermore…
…of 12 has shut. Expert reports have been exchanged, so Ms. Giuffre’s experts did not have the benefit of reviewing these documents. Late production of this information robs Ms. Giuffre of any practical ability to use the discovery, and…
…119 (2d Cir. 2006). The Second Circuit has explained that “documents that directly affect an adjudication and play a significant role in determining litigants’ substantive rights receive the benefit of a relatively strong presumption, while the public interest in other…
…or defense; and documents that are not proportional to the needs of the case. Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such discovery is prohibited by the Federal Rules of Civil Procedure, particularly under…
…Mar. 25, 2021). 3 There is no basis to believe that the protective order or subsequent sealing of documents were imposed solely for Maxwell’s benefit; Judge McMahon discussed “Maxwell[’s] … degree of pro- tection” because she “assume[d]…
…be unreasonably cumulative or duplicative, the requesting party had a prior opportunity in discovery to obtain the information sought, or the burden or expense of additional depositions would outweigh any likely benefit.” In re Weatherford Int'l Sec. Litig., No…
…would be both untimely and prejudicial. Fact discovery has closed. Numerous depositions have already been taken by Ms. Giuffre without the benefit of these documents. The window for authenticating the documents through depositions has shut. Expert reports are due at…
…that that counsel feels must be redacted, can 13 it be just redacted? 14 THE COURT: Of course. 15 MS. WALZ: So we can have the benefit of the chart. 16 THE COURT: Of course. Yes, indeed. 17 And, counsel…
…sanctions, “to ‘ensure that a party will not benefit from its own failure to comply,’ to ‘obtain compliance with a particular order issued,’ and to ‘serve a general deterrent 4 Plaintiff lodged an objection to communications regarding “ongoing” investigations, but…
…followed in this case. While requiring Mr. Epstein to invoke his Fifth Amendment privilege in front of the jury will yield not even a marginal benefit to either party, there are substantial countervailing concerns that weigh heavily against requiring Mr…
…be unreasonably cumulative or duplicative, the requesting party had a prior opportunity in discovery to obtain the information sought, or the burden or expense of additional depositions would outweigh any likely benefit.” In re Weatherford Int'l Sec. Litig., No…
…untimely and prejudicial. Fact discovery has closed. Numerous depositions have already been taken by Ms. Giuffre without the benefit of these documents. The window for authenticating the documents through depositions 7 has shut. Expert reports have been exchanged, so Ms…
…orders is broad. “When the district court invokes its inherent power to sanction misconduct by an attorney that involves that attorney’s violation of a court order or other misconduct that is not undertaken for the client’s benefit, the …
…he had no role in issuance of the statement, he has no benefit in the outcome of this litigation and he played no controlling role in its respect. Similarly, there is not any evidence at all to support an adverse…
…would be both untimely and prejudicial. Fact discovery has closed. Numerous depositions have already been taken by Ms. Giuffre without the benefit of these documents. The window for authenticating the documents through depositions has shut. Expert reports are due at…
…add any clarity to the process. Approaching the Does in categories will have the added benefit of having only a few responses and replies due in a particular round as the Objecting Does will be spread out amongst the groups…
…or defense; and documents that are not proportional to the needs of the case. Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such discovery is prohibited by the Federal Rules of Civil Procedure, particularly under…
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