…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…
…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…
…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…
…participation. And, indeed, precedent mandates the protocol’s approach: “[t]he job of protecting [non- party privacy rights] rests heavily upon the shoulders of the trial judge.” In re New York Times Co., 828 F.2d 110, 116 (2d Cir…
…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 …
…they're specifically talking 20 about here. 21 THE COURT: Thank you very much. I will reserve 22 decision. 23 The motion to quash the Epstein -- 24 MR. POE: May I approach the podium, your Honor? 25 THE COURT: Yes…
…not oppose Dershowitz’s motion is of no moment. Indeed, it proves the point, by underscoring the caution with which the Court should approach Dershowitz’s request. And, in any event, a non-party that produces information in discovery remains…
…was “amenable to unsealing portions of documents mentioning non-parties rather than waiting to unseal the entirety of a given document until all non-parties have provided input.” Intervenors ask that the Court follow the approach set forth in Dkt…
…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…
…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…
…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…
…and all of that. 8 MR. PAGLIUCA: Exactly. 9 So, your Honor, if I could approach, I wanted to talk 10 about the nonprosecution agreement and why the nonprosecution 11 agreement, I think, ends this discussion. 12 In order to…
…a crime victim. Plaintiff and Ms. Maxwell have a fundamental difference in the approach to identifying the non-parties who should be on the list. Plaintiff takes the position that if a non-party’s name has appeared anywhere in…
…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…