giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…not proportional to the
needs of the case. Such requests would create a heavy burden on Ms. Giuffre that outweighs any
benefit. Such discovery is prohibited by the Federal Rules of Civil Procedure, particularly under
the 2015 amendments to Rule…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.29_1
16 pg
…not proportional to the
needs of the case. Such requests would create a heavy burden on Ms. Giuffre that outweighs any
benefit. Such discovery is prohibited by the Federal Rules of Civil Procedure, particularly under
the 2015 amendments to Rule…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…or defense; and documents that are not proportional to the needs of the case.
Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such discovery
is prohibited by the Federal Rules of Civil Procedure, particularly under…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…Inc., 285 B.R. 101, 109
(E.D.N.Y. 2002) (quoting United States v. Peoples Benefit Life Ins. Co., 271 F.3d 411, 415 (2d
Cir. 2001)).
Under Rule 24(b), courts in this Circuit consider the following factors…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…confidence in the administration of justice.”). Indeed, the motion to intervene is
devoid of any citations to precedent that allows an individual to exploit these bedrock legal
principles solely for his personal benefit, rather than the public at large. Furthermore…
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.447706.1307.4
28 pg
…be unreasonably
cumulative or duplicative, the requesting party had a prior opportunity in discovery to obtain the
information sought, or the burden or expense of additional depositions would outweigh any
likely benefit.” In re Weatherford Int'l Sec. Litig., No…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…be unreasonably
cumulative or duplicative, the requesting party had a prior opportunity in discovery to obtain the
information sought, or the burden or expense of additional depositions would outweigh any
likely benefit.” In re Weatherford Int'l Sec. Litig., No…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.17
13 pg
…orders is broad. “When the district court
invokes its inherent power to sanction misconduct by an attorney that involves that attorney’s
violation of a court order or other misconduct that is not undertaken for the client’s benefit, the
…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…would be both untimely and prejudicial. Fact discovery has closed.
Numerous depositions have already been taken by Ms. Giuffre without the benefit of these
documents. The window for authenticating the documents through depositions has shut. Expert
reports are due at…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.23
9 pg
…denying Ms. Giuffre the benefit of being able to use these e-
mails at multiple witness depositions. The only “untimeliness” claim that can be made here is against
1111
the Defendant.
-
The two emails in question are responsive to a…
giuffre-maxwell
gov.uscourts.nysd.447706.68.0
17 pg
…lawsuit is lost income. Her Rule 26 disclosure of the basis for calculating these damages was
extensive and is worth setting out here for the benefit of the Court:
Estimated lost income of $180,000 annually. Present value of $3…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…be unreasonably
cumulative or duplicative, the requesting party had a prior opportunity in discovery to obtain the
information sought, or the burden or expense of additional depositions would outweigh any
likely benefit.” In re Weatherford Int'l Sec. Litig., No…
giuffre-maxwell
gov.uscourts.nysd.447706.364.0
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.447706.1256.3
28 pg
…be unreasonably
cumulative or duplicative, the requesting party had a prior opportunity in discovery to obtain the
information sought, or the burden or expense of additional depositions would outweigh any
likely benefit.” In re Weatherford Int'l Sec. Litig., No…
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.447706.406.0
31 pg
…confidence in the administration of justice.”). Indeed, the motion to intervene is
devoid of any citations to precedent that allows an individual to exploit these bedrock legal
principles solely for his personal benefit, rather than the public at large. Furthermore…
giuffre-maxwell
1320-10
28 pg
…be unreasonably
cumulative or duplicative, the requesting party had a prior opportunity in discovery to obtain the
information sought, or the burden or expense of additional depositions would outweigh any
likely benefit.” In re Weatherford Int'l Sec. Litig., No…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.22
31 pg
…confidence in the administration of justice.”). Indeed, the motion to intervene is
devoid of any citations to precedent that allows an individual to exploit these bedrock legal
principles solely for his personal benefit, rather than the public at large. Furthermore…
giuffre-maxwell
gov.uscourts.nysd.447706.71.3
40 pg
…or defense; and documents that are not proportional to the needs of the case.
Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such discovery
is prohibited by the Federal Rules of Civil Procedure, particularly under…