giuffre-maxwell
gov.uscourts.nysd.447706.1330.17
12 pg
…whether the party
requesting the deposition has had other opportunities to obtain the same information, and
whether the burden of a second deposition outweighs its potential benefit.’” Id. (quoting Ganci,
1
Case 1:15-cv-07433-LAP Document 1330…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…he had no role in issuance of the statement, he has
no benefit in the outcome of this litigation and he played no controlling role in its respect.
Similarly, there is not any evidence at all to support an adverse…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…Numerous depositions have already been taken by Ms. Giuffre without the
benefit of these documents. The window for authenticating the documents through depositions
7
Case 1:15-cv-07433-LAP Document 1332-1 Filed 01/08/24 Page 9…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.18
11 pg
…make a convoluted legal argument, not to actually seek
discoverable information. In light of this, the “burden or expense of the proposed discovery
outweighs its likely benefit, considering the needs of the case, the parties' resources, the
importance of the…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…119 (2d Cir.
2006). The Second Circuit has explained that “documents that directly affect an adjudication
and play a significant role in determining litigants’ substantive rights receive the benefit of a
relatively strong presumption, while the public interest in other…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.13_1
19 pg
…sanctions, “to ‘ensure that a party will not benefit from its own failure to
comply,’ to ‘obtain compliance with a particular order issued,’ and to ‘serve a general deterrent
4
Plaintiff lodged an objection to communications regarding “ongoing” investigations, but…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.18
50 pg
…s defamatory statements is not appropriate under Rule 26(b)(1), which
takes into account “whether the burden or expense of the proposed discovery outweighs the
likely benefit.” Here, scouring the Internet for additional examples of the publication of the
…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.20
11 pg
…make a convoluted legal argument, not to actually seek
discoverable information. In light of this, the “burden or expense of the proposed discovery
outweighs its likely benefit, considering the needs of the case, the parties' resources, the
importance of the…
giuffre-maxwell
1320-20
11 pg
…make a convoluted legal argument, not to actually seek
discoverable information. In light of this, the “burden or expense of the proposed discovery
outweighs its likely benefit, considering the needs of the case, the parties' resources, the
importance of the…
giuffre-maxwell
1320-28
32 pg
…he had no role in issuance of the statement, he has
no benefit in the outcome of this litigation and he played no controlling role in its respect.
Similarly, there is not any evidence at all to support an adverse…
giuffre-maxwell
gov.uscourts.nysd.447706.189.0
11 pg
…make a convoluted legal argument, not to actually seek
discoverable information. In light of this, the “burden or expense of the proposed discovery
outweighs its likely benefit, considering the needs of the case, the parties' resources, the
importance of the…
giuffre-maxwell
gov.uscourts.nysd.447706.29.1
18 pg
…cv-07433-RWS
2:15-cv-01658-AJS Document
Document 29-1
19 Filed
Filed01/21/16
01/22/16 Page
Page3 3ofof1818
…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.19_2
32 pg
…he had no role in issuance of the statement, he has
no benefit in the outcome of this litigation and he played no controlling role in its respect.
Similarly, there is not any evidence at all to support an adverse…
giuffre-maxwell
gov.uscourts.nysd.447706.269.0
19 pg
…sanctions, “to ‘ensure that a party will not benefit from its own failure to
comply,’ to ‘obtain compliance with a particular order issued,’ and to ‘serve a general deterrent
4
Plaintiff lodged an objection to communications regarding “ongoing” investigations, but…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.6
32 pg
…119 (2d Cir.
2006). The Second Circuit has explained that “documents that directly affect an adjudication
and play a significant role in determining litigants’ substantive rights receive the benefit of a
relatively strong presumption, while the public interest in other…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…Instead, she seeks
-
the drastic and improper sanction of an adverse inference knowing that it is far more beneficial to
-
her than actually receiving information from EarthLink whi…
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