…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…
…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…
…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…
…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…
…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…
…3. The government could have been, but was not, more targeted in its approach. The government has not provided Maxwell with a copy of the subpoena, but the record shows that the subpoena was incredibly broad and, as explained below…
…be unsealed and docketed in the form that they were 8 received from the law enforcement agency. This is also 9 consistent with the approach that the Court of Appeals has 10 taken. Consistent with the Court of Appeals' approach…
… And CW then contacts the 18 FBI; and the FBI sets up a sting operation to indict 19 Mr. Rodriguez. 20 If I can approach, your Honor, I'd like to talk a 21 little bit about the affidavit that…
…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…
…of the discovery from Maxwell,”” he has not beyond conclusory assertions demonstrated a congruence between the Maxwell action and his own that would warrant such an indiscriminate approach. A brief comparison of the Maxwell and Dershowitz actions makes this clear…
…proffer as to how the question was within the Court’s Order, the question was withdrawn and a different question was posed: “Mr. Boies: Let me approach it this way.” … Did Ms. Ward tell you that?” The questioning about …
…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…
Comments