…will add to our log. We also located a number of privileged communications between our client and myself following the onset of litigation in this case which will not be logged consistent with both parties' agreed to practice. As predicted…
…to revisit the same document for each non-objecting Doe. That certain Non-Parties have not been located does not detract from this point. Consistent with the Protocol, Parties used their “best efforts” to attempt service and, in any event…
…objecting Non-Party; all references to other objecting Non-Parties referenced in the brief will be redacted prior to ‘serving’ the brief on the objecting Non-Party consistent with subparagraph (d) above.” The addition of this language is unnecessary, however…
…1026 at 3. We object. Plaintiff did not confer with us about this proposal. She offers no rationale for it. The Court consistently has permitted replies in these proceedings. See, e.g., Docs. 996 & 997. Since the objectors have the…
…Maxwell, 929 F.3d 41 (2d Cir. 2019), the Second Circuit released “the summary judgment materials,” which consisted of the defendant’s motion for summary judgment, the parties’ memoranda of law, and supporting exhibits. Upon the issuance of its mandate…