…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…
…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…
…Maxwell’s deposition or Doe 1’s deposition, regardless of whether those motions mention Doe 1 or Doe 2. Plaintiff disagrees with this approach, as the parties agreed and the Court ordered that the Protocol would proceed by Non- Party…
…commenced” . . . and the moving party “ha[d] not listed with specificity those individuals it wishes to depose.” Of course, neither of these points applies in this case at hand: the parties are approaching the close of fact discovery, and Ms…
…commenced” . . . and the moving party “ha[d] not listed with specificity those individuals it wishes to depose.” Of course, neither of these points applies in this case at hand: the parties are approaching the close of fact discovery, and Ms…
…commenced” . . . and the moving party “ha[d] not listed with specificity those individuals it wishes to depose.” Of course, neither of these points applies in this case at hand: the parties are approaching the close of fact discovery, and Ms…