…as it applies to Doe 1 and Doe 2’s recent communication and the related deadlines for objecting and responding. After conferral with Plaintiff’s counsel, the parties were unable to reach an agreement. Depending on the Court’s clarification…
…July 14, 2016 11:22 AM To: 'Brad Edwards' Subject: RE: Your motions Brad, I after our conversation last week I thought that you understood that we did not agree with the 344 search terms that Ms. Schultze unilaterally imposed…
…the Protocol suggest that the 7-day clock is not yet running. As Ms. Maxwell points out, the Protocol contemplates specifically that a non-party has 14 days to object to unsealing after service of the relevant excerpts, (dkt. no…
…released once and need not be revisited. The only remaining documents requiring review after that will be documents referencing non-objecting Does that do not include references to objecting Does. Much of Ms. Maxwell’s submission focuses on her desire…
…particularly given the significant privacy interests implicated. The Protocol ordered by the Court, after substantial input from the parties, is achieving its desired purpose of: (a) attempting to provide notice and an opportunity to object to non-parties to the…
…660 and 660-1 were scheduled for argument on April 13, 2017, counsel argued the motion for 75 pages worth of transcript that day, after which Judge Sweet stated, “Thank you all. I will reserve decision.” The motion was never…
…not know the ages of the 7 various massagists, right? 8 A. No. 9 Q. Did you have occasion to clean up after 10 the massages? 11 A. Yes. 12 Q. Okay. And that is after both a massage 13 …
…wit, that Ms. Maxwell “assisted” and participated in sexual abuse of the Plaintiff between 1999 and 2002. Plaintiff does not claim that any sexual abuse occurred after 2002 or that she had any contact with Ms. Maxwell after 2002. Indeed…
…and 2 at this time, Plaintiff understands that any oppositions to those Non-Party Objections are not due until 7 days after the Court indicates that it will review sets of motions for those Does. Proceeding this way allows the…
…unsealing” and, at Plaintiff’s urging,1 the Court ruled that “[a]ny oppositions to those Non-Party Objections are not due until 7 days after the Court indicates it will review sets of motions for those Does.” Id. at…
…and requested an extension of the deadline for the parties’ first briefs until January 31. Other than Judge Nathan’s statement that the trial may last until after the holidays, Plaintiff is Case 1:15-cv-07433-LAP Document…
… LEWIN: Yes, your Honor. Good afternoon. I hope 19 you and everyone are doing well. 20 This is Nick Lewin on behalf of John Doe. And Paul 21 Krieger is also on the line from Krieger Kim & Lewin. 22 THE…
…by the Court based on agreed to search terms, including those agreed to in our conferral yesterday. After review of more than 9,000 documents and files containing your search terms, the only documents located not previously produced are 6…
…Dkt. 1087 at 2–3. Nor did Maxwell’s counsel offer to provide the Court with a competing set of proposed redactions for in camera review until the afternoon of the Court-ordered deadline to unseal. Even then, Maxwell’s…
…15-cv-07433-LAP Document 1157 Filed 11/20/20 Page 4 of 5 oppositions to those Non-Party Objections are not due until 7 days after the Court indicates that it will review sets of motions for those Does…
…also asked whether there should 2 At meet and confer, Maxwell discussed the future burden of preparing redactions after the Court rules on the Non-Party Objections. But the logistics of mechanically implementing the Court’s eventual order for these…
…Civ. P. 26(g)(1) (requiring discovery responses to be “to the best of the person’s knowledge, information, and belief formed after a reasonably inquiry.”). See also Moore v. Publicis Groupe, 287 F.R.D. 182,188 (S.D…
… Defendant Has Repeatedly Refused to Confer Regarding Their Document Collection Process After an unequivocal and flat refusal to discuss her ESI protocols (“ [w]e do not believe we have an obligation to describe for your [sic] our document search methods…
…those Non-Party Objections. Any oppositions to those Non-Party Objections are not due until 7 days after the Court indicates that it will review sets of motions for those Does. The Court will update the Protocol and file a…