…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…
…so 20 that I don't have to say it out loud. It is certain pieces 21 that we have already provided that have been attached to our 22 filings but in summary form. 23 If I can approach? 24 …
…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…
…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…