giuffre-maxwell
gov.uscourts.nysd.447706.89.0
10 pg
…to
disqualify counsel). Indeed, “courts have in recent years become more and more skeptical of
motions to disqualify counsel, and they now approach them with cautious scrutiny.” Laker
Airways Ltd., 103 F.R.D. at 28. See also Ragdoll Prods…
giuffre-maxwell
gov.uscourts.nysd.447706.1248.0
6 pg
…to
allow her defense witnesses to use pseudonyms, as they were not testifying as victims of sexual
abuse). “Implicit in this approach is a balancing of the victim’s privacy interest, on one hand, and
the public interest in access…
giuffre-maxwell
gov.uscourts.nysd.447706.68.0
17 pg
…a necessary
9
Case 1:15-cv-07433-LAP Document 68 Filed 03/23/16 Page 13 of 17
predicate for application of this kind of approach is some evidence of prior employment history.
That is not necessarily true…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…P. 11. See also Amodeo II, 71 F.3d at 1049 (describing sanctions available
to the court).
45 Sonia Sotomayor & Nicole A. Gordon, Returning Majesty to the Law and
Politics: A Modern Approach, 30 Suffolk U. L. Rev. 35, 47…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.50
15 pg
…support of any
part of the court’s adjudicatory function.” Rosado, 970 A.2d at 678 (emphasis added)
(describing the Second Circuit’s approach as consistent with Mokhiber). This explains the nearly
uniform consensus among the district courts bound by…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.18
23 pg
…7 Thank you .
8 MS. McCAWLEY : Good morning, your Honor. May I
9 approach with a bench book?
10 THE COURT : Sure .
11 MS. MCCAWLEY : Thank you.
12 THE COURT: I think in duplicate . Do you have another
13 copy…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
…Epstein often settles lawsuits out of court. She has
22 testified that she read that statement and decided to approach
23 the reporter to try to sell her story. She did that just a
24 couple weeks before she called…
giuffre-maxwell
gov.uscourts.nysd.447706.364.0
32 pg
…Circuit has never adopted such a rule, and
the weight of district court authority in the Southern District of New York rejects this approach.
16
memorandum of law” seeking to limit discovery “clearly constitute ‘judicial documents’”); In re
Omnicom Grp…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…at 119-20. It is a given
accepted by the Protective Order that the trial and all trial
documents are accessible and public absent special
circumstances.
Under the common law approach, once a document is
classified as a judicial document…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…To
leave the discovery until later would be burdensome on the jury – meaning that a common
approach is to allow financial discovery to proceed pre-trial and then to later bifurcate the trial
itself into liability and punitive damages phases…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.18_1
40 pg
…8 Q. And how did you meet her?
9 A. She approached me while I was on campus at
10 Palm Beach Atlantic College.
11 Q. And what happened when she approached you?
12 A. She asked me if I…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.17
12 pg
…As she is trying to explain, and
11 I'm asking questions because I'm as feared as
12 she is at this point. We hear people
13 approach and she just shuts up.
14 Q. What happens next?
15 …
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…To
leave the discovery until later would be burdensome on the jury – meaning that a common
approach is to allow financial discovery to proceed pre-trial and then to later bifurcate the trial
itself into liability and punitive damages phases…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.14_2
40 pg
…discussed
below, as a matter of controlling federal authority, these cases have been repudiated by the
Second Circuit. And to the same effect, Florida law also rejects the expansive Hearn approach
to waiver. See Guarantee Ins. Co. v. Heffernan Ins…
giuffre-maxwell
gov.uscourts.nysd.447706.563.0
10 pg
…This Court has
also explained that a party cannot use a mix-and-match approach of combining part live
testimony and part recorded testimony for a witness: “Rule 32 was intended to provide deposition
use as a substitute for live…
giuffre-maxwell
gov.uscourts.nysd.447706.634.0_2
15 pg
…motion, attached to the plaintiff's reply motion in the copy I
13 received, your Honor.
14 MS. McCAWLEY: Your Honor, if I can approach, I can
15 hand you a copy of that.
16 THE COURT: Okay. Fine. Thanks…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…been categorical and succinct. It was neither. The decision turned on the Second Circuit’s lengthy
discussion of the First and Third Circuits’ divergent approaches to the question, when is a mere
document transformed into a judicial one? The Third…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…DE 282 at 2. But Jane Doe No. 3 was simply following the same approach that Jane
Doe No. 2 had taken earlier, by filing a motion to join rather than a proposed amendment to pleadings.
6
Case 1…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.12
223 pg
…four hours in my mind is
13 not a hard and fast four hours based upon how we
14 proceed in this deposition. So I'll take that
15 into consideration as we approach the four hours.
16 A. Yes…
giuffre-maxwell
gov.uscourts.nysd.447706.849.0
94 pg
…contains the seal
21 of the FBI at the top of it. It contains the date. Can I
22 approach, please.
23 It's a document that's commonly used when FBI agents
24 are conducting their investigations; in fact…
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