…As a result, John Doe is in no position to speculate (let alone dictate) how the Court should approach and consider the categories of documents that the parties have agreed upon, to say nothing of offering wholly new categories for…
…2016. Ms. Maxwell has twice sat for deposition, approaching 13 hours on the record, far more than the presumptive 7 hour limit under the Federal Rules. During that time, Plaintiff has had a full and fair opportunity to depose Ms…
…Dkt. 279: Motion for Adverse Inference Instruction, Dkt. 345: Motion to Compel Production of Documents Subject to Improper Objection, and Dkt. 659: Second Motion to Compel. To illustrate the utility of this approach, at the March 31, 2020, conference, the…
…The parties in Dershowitz have done just that and have presented a “reasonable” approach in which Giuffre has no objection to producing certain enumerated categories from among the Maxwell confidential materials and sealed filings in her possession so long as…
…2020 Tr. 4:3-16. Plaintiff contends that Defendant’s approach contravenes the Court’s ruling, which (as did the Second Circuit) unsealed the documents subject to limited redactions. Given the parties’ disagreement, Plaintiff will send her proposed redactions to…
…ideas that we have come up 17 with -- we have submitted the letter to you, obviously, which 18 poses an approach dealing with the non-parties. One other 19 piece of that, if it would be beneficial to the Court…
…here. Indeed, she cannot approach that standard, as she has made no showing whatsoever of any compelling or particularized need for these materials. Defendant is attempting to improperly interfere with an ongoing criminal investigation, and under New York law, disclosure…
…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…
…might be at the very bottom of the Non- Party list. The Court would need to make 15 separate rulings before Docket Entry 143 is unsealed. s approach, all Non-Parties mentioned in the First Five Motions would be notified…
…Plaintiff’s counsel proposes an ad hoc approach in which filings appear to be selected in order to speed up review of materials that Plaintiff would like to see unsealed first rather than a review method that favors efficiency and…
…2017, followed up on this by presenting argument on the Motion to Compel that relied almost entirely on the rules-violating reply. Because of the unfairness from plaintiff’s chaotic approach to motion practice, we requested on March 9 leave…
…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…
…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…
…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…
…Honor, 4 of just making a very short little cheat sheet of the 5 outstanding issues, if I may approach. 6 THE COURT: Yes. It will be interesting to see if 7 yours is the same as the one we…
…Plaintiff’s ad hoc approach that picks and chooses among Non-Parties will more likely to lead to confusion and inefficiency in lieu of an orderly and logistical progression of unsealing. Defendant instead offers two alternatives for selecting the pleadings…
…the order that their name appears on the Non-Party list. Id. at 1-2. Under Maxwell’s approach, the public will not have access to those documents, to which they have a First Amendment right of access, for years…
…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…
…2019) (quoting Newsday LLC v. County of Nassau, 730 F.3d 156, 163 (2d Cir. 2013)). In the Second Circuit, courts utilize two methods approaching the First Amendment right. Doe, 2019 U.S. Dist. LEXIS 36605, at *3. The “experience…
…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…
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