gov.uscourts.nysd.447706.165.1.pdf PDF
…to any party’s claim or defense, are not proportional to the needs of the case, and creates a heavy burden on…
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gov.uscourts.nysd.447706.156.7.pdf PDF
…are not relevant to any party’s claim or defense, are not proportional to the needs of the case, and creates …
gov.uscourts.nysd.447706.1330.17.pdf PDF
…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…
gov.uscourts.nysd.447706.1328.5.pdf PDF
…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…
gov.uscourts.nysd.447706.1006.0.pdf PDF
…Therefore, the Court can have the benefit of whichever format it prefers to work from. Plaintiff’s format includes the specifics of sealed orders and details of the sealed exhibits for ease of the Court’s reference and accordingly is…
gov.uscourts.nysd.447706.1218.38.pdf PDF
…on privilege, he wagered that the consequences from this Court for his deliberate violation of the settlement privilege would not be harsh enough to offset the benefit he received by feed ing fa lse information to the press. On December…
gov.uscourts.nysd.447706.639.0.pdf PDF
…455 at 2. In the interests of judicial economy, the parties believe it would be appropriate to have the benefit of the Court's rulings on these other issues, review the designated testimony in light of such rulings and then…
gov.uscourts.nysd.447706.1198.29_1.pdf PDF
…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…
gov.uscourts.nysd.447706.1331.12.pdf PDF
…Simply put, she should not be allowed to benefit from her obvious failure to properly disclose Ms. Ransome. Ms. Ransome's Testimonv is ot Cumulative And Has Highly Relevant Evidence Defendant also advances the remarkable argument that it is "unlikely…
gov.uscourts.nysd.447706.1218.37.pdf PDF
…for his deliberate violation of the settlement privilege will not be harsh enough to offset the benefit he received by feeding false Case 1:15-cv-07433-LAP Document 1218-37 Filed 07/15/21 Page 3 of 9 …
gov.uscourts.nysd.447706.1045.0.pdf PDF
…it references J. Doe 1 or 2, so that the Court has the benefit of the “Related Docket #” column listing the related filings. Ms. Maxwell submits that consideration of the motions in chronological order is the most logical, efficient and…
gov.uscourts.nysd.447706.441.0.pdf PDF
…in resolvingthe issu es,and whetherthe bu rd en orex pense of the proposed d iscovery ou tweighs its likely benefit. Ru le 26(b)(1),Fed .R.C iv.P .D efend ant’s d iscovery requ ests foremploymentand…
gov.uscourts.nysd.447706.1332.1.pdf PDF
…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…
gov.uscourts.nysd.447706.1090.18.pdf PDF
…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…
gov.uscourts.nysd.447706.1332.14.pdf PDF
…for two hour on each subject, up to a total of four hours. The Defendant should not get a benefit from having twice improperly withheld information, by collapsing the two hours needed to address each of these topics into an…
gov.uscourts.nysd.447706.1219.33.pdf PDF
…of 12 has shut. Expert reports have been exchanged, so Ms. Giuffre’s experts did not have the benefit of reviewing these documents. Late production of this information robs Ms. Giuffre of any practical ability to use the discovery, and…
gov.uscourts.nysd.447706.1200.11_1.pdf PDF
…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…
gov.uscourts.nysd.447706.1198.13_1.pdf PDF
…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…
gov.uscourts.nysd.447706.1331.36.pdf PDF
…followed in this case. While requiring Mr. Epstein to invoke his Fifth Amendment privilege in front of the jury will yield not even a marginal benefit to either party, there are substantial countervailing concerns that weigh heavily against requiring Mr…
gov.uscourts.nysd.447706.1330.11.pdf PDF
…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 7 has shut. Expert reports have been exchanged, so Ms…
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