…And Dismiss Counts Five And Six, Which Are The Fruits Of That Evidence .......................................................................................................................... 11 1. The role of protective orders in civil litigation. .......................................................... 11 …
…Martindell requires suppression. By issuing a , the government circumvented the Second Circuit’s 11 Case 1:15-cv-07433-LAP Document 1206-13 Filed 02/04/21 Page 16 of 22 decision in Martindell v. International Telephone & T…
…on this date, as Docket Entry 1021. Dershowitz has long advocated for unsealing and transparency in this matter. To circumvent potential reporting inaccuracies and misplaced assumptions, the unsealing of Docket Entry 1026-3 will be beneficial to the Intervenors, media…
…4 B. The USVI Offers No Reason to Circumvent the Court’s Unsealing Process To the extent that the USVI is seeking access to sealed materials beyond what was unsealed by the Second Circuit, the carefully constructed protocol established by…
…their proposed modifications to the Dershowitz Protective Order. We initially raised objections to the Dershowitz Protective Order owing to a concern that it constituted another effort by the Dershowitz parties to circumvent the Protocol and the ongoing process proceeding thereunder…
…it should deny this one. 1 A. This Court’s Rejection of Dershowitz’s Initial Attempts to Oppose or Circumvent the Protocol Earlier this year, after substantial input from and discussion with the parties, the Court finalized the protocol for…
…2001)). This rule is in place because “a party could indirectly circumvent the cap on depositions by exhausting the maximum allotted number to those that she could not justify under the Rule 26(b)(2) standards, and then seek[ ] leave…
…lawyer or witness who finds that a deposition is going in an undesirable or unanticipated direction could simply insist on a short recess to discuss the unanticipated yet desired answers, thereby circumventing the prohibition on private conferences. Id. (emphasis added)…
…11 opportunity to review for attorney-client privilege email, 12 review for relevance, and it wholly circumvents the protections 13 of the discovery process, which is why courts who have looked 14 at this issue have consistently rejected these broad…
…The Court pointed out the problem with such an order: [E]ach party could circumvent the "good cause" standard for protection and simultaneously shift the burden to his adversary to unseal a document while benefitting from the more rigorous "extraordinary…
…transcripts to the government, which then charged Ms. Maxwell with perjury counts, suggest plaintiff in conjunction with the government sought to circumvent Martindell: they set a perjury trap for Ms. Maxwell when plaintiff took her deposition. Ms. Maxwell requests that…
…2001)). This rule is in place because “a party could indirectly circumvent the cap on depositions by exhausting the maximum allotted number to those that she could not justify under the Rule 26(b)(2) standards, and then seek[ ] leave…
…2001)). This rule is in place because “a party could indirectly circumvent the cap on depositions by exhausting the maximum allotted number to those that she could not justify under the Rule 26(b)(2) standards, and then seek[ ] leave…
…2001)). This rule is in place because “a party could indirectly circumvent the cap on depositions by exhausting the maximum allotted number to those that she could not justify under the Rule 26(b)(2) standards, and then seek[ ] leave…
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