…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…
…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…
…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…
Comments