giuffre-maxwell
1320-33
24 pg
…Rule 26(a)(iii) requires the Plaintiff to provide “a computation of each category of damages claimed by
the disclosing party—who must also make available for inspection and copying as under Rule 34 the
documents or other evidentiary material…
giuffre-maxwell
gov.uscourts.nysd.447706.57.3
39 pg
…up
the investigation was to prepare for contemplated legal proceedings, it would
not be appropriate to order inspection of the documents on the ground that the
defendants had not satisfied the burden of proof. The affidavits did not disclose
G …
giuffre-maxwell
gov.uscourts.nysd.447706.1219.8
29 pg
…v. Kent State Univ., No. 5:08 CV 720, 2012 WL 6084630, at **3-4 (N.D. Ohio
Dec. 6, 2012) ................................................................................................................... 9
Generac Power Sys. v. Kohler Co., 2012 WL 5463913, at *2 (E.D. Wis. Nov. 8, 2012) .. 9…
giuffre-maxwell
gov.uscourts.nysd.447706.1351.0
32 pg
…17, 2024 notices of appeal in this case untimely by several years.
Maxwell Br. at 14–18. We are not persuaded.
Appellate jurisdiction generally exists only over the “final decisions
of the district courts,” 28 U.S.C. § 1291, and…
giuffre-maxwell
gov.uscourts.nysd.447706.56.0
14 pg
…18, 2014) .................................4
ii
USP Strategies v. London General Holdings Ltd.,
[2004] EWHC 373 (Ch) ..........................................................................................................5, 6
Waugh v. British Railways Board,
…
giuffre-maxwell
gov.uscourts.nysd.447706.551.0
17 pg
…Litowitz Berger & Grossmann LLP, 814 F.3d 132, 142 (2d Cir. 2016) (“The courts have long
recognized the “general right to inspect and copy public records and documents, including judicial
records and documents.”) (citing Nixon, 435 U.S. at 597…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…121 (2d Cir. 2006). We
observe that our holding in Lugosch relies on the general principle that parties may
“be assumed to have supported their papers with admissible evidence and non‐
frivolous arguments.” Id. at 122. Insofar as a district…
giuffre-maxwell
gov.uscourts.nysd.447706.978.0
27 pg
…121 (2d Cir. 2006). We
observe that our holding in Lugosch relies on the general principle that parties may
“be assumed to have supported their papers with admissible evidence and non‐
frivolous arguments.” Id. at 122. Insofar as a district…
giuffre-maxwell
gov.uscourts.nysd.447706.936.0
21 pg
…LLP, 814 F.3d 132, 142 (2d Cir. 2016). In Bernstein, the Second Circuit emphasized the "general
right to inspect and copy…judicial records and documents." Id. at 142 (quoting Nixon v. Warner
Commc'ns, Inc., 435 U.S…
giuffre-maxwell
gov.uscourts.nysd.447706.33.0
19 pg
…Maxwell, has failed to comply with Local Rule
26.2(a)(2)(B), which requires that “the general subject matter of the communication” be stated in
the privilege log. The “subject matter” is not stated; it does not even indicate…
giuffre-maxwell
gov.uscourts.nysd.447706.1118.0
21 pg
…“[c]ourts
generally apply one of three standards when faced with a request to modify a protective order.
The Martindell standard is generally applicable when a government agency seeks modification
of a protective order governing discovery in a civil action…
giuffre-maxwell
gov.uscourts.nysd.447706.1155.0_2
13 pg
…Yet, with this second batch of documents, Ms. Maxwell offers only the same repackaged
generalized arguments, which this Court and the Second Circuit have already rejected as
insufficient to support the continued sealing of documents in this matter. Giuffre, 827…
giuffre-maxwell
gov.uscourts.nysd.447706.977.0
27 pg
…121 (2d Cir. 2006). We
observe that our holding in Lugosch relies on the general principle that parties may
“be assumed to have supported their papers with admissible evidence and non‐
frivolous arguments.” Id. at 122. Insofar as a district…
giuffre-maxwell
gov.uscourts.nysd.447706.1349.0
31 pg
…17, 2024 notices of appeal in this case untimely by several years.
Maxwell Br. at 14–18. We are not persuaded.
Appellate jurisdiction generally exists only over the “final decisions
of the district courts,” 28 U.S.C. § 1291, and…
giuffre-maxwell
gov.uscourts.nysd.447706.1253.0
12 pg
…158 (1945) (“Moreover, we are not prepared to concede that the general
right of inspection of public records enables one in every instance to publish such records broadcast
without regard to the truth of defamatory matter contained in them.”). Here…
giuffre-maxwell
gov.uscourts.nysd.447706.231.0
23 pg
…Rule 26(a)(iii) requires the Plaintiff to provide “a computation of each category of damages claimed by
the disclosing party—who must also make available for inspection and copying as under Rule 34 the
documents or other evidentiary material…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…nothing to do with privilege logs and, in fact, holds to the contrary: “The permissible
scope of discovery from a non-party is generally the same as that applicable to discovery sought
from parties.” Wells Fargo Bank, N.A. v…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.9
15 pg
…nothing to do with privilege logs and, in fact, holds to the contrary: “The permissible
scope of discovery from a non-party is generally the same as that applicable to discovery sought
from parties.” Wells Fargo Bank, N.A. v…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…court. It holds “that when a court has ruled on an issue, that
decision should generally be adhered to by that court in subsequent stages in the
same case,” unless “cogent” and “compelling” reasons militate otherwise.
United States v. Quintieri…
giuffre-maxwell
gov.uscourts.nysd.447706.179.0
22 pg
…support Defendant, and the Court should
deny Ms. Maxwell’s motion in its entirety.
FACTUAL BACKGROUND
While the Defendant alludes generally to “inadequacies” in Ms. Giuffre’s privilege log,
she does not specifically discuss those inadequacies in her pleading. For…