Found 19 results for “consistent” in 222ms

gov.uscourts.nysd.447706.1285.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1285.0 6 pg

…Doe 171 respectfully requests that this Court provide modest relief from its ore tenus unsealing order to remain consistent with its treatment of other Non-Party Does who continue to experience trauma as a result of the events that are…

gov.uscourts.nysd.447706.1046.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1046.0 3 pg

…unsealing process moves forward efficiently and swiftly, and is consistent with the goal of satisfying the public’s right of access to the information it seeks in as expeditious a manner as possible. Plaintiff understands that Maxwell will argue that…

gov.uscourts.nysd.447706.1286.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1286.0 6 pg

…Doe 171 respectfully requests that this Court provide modest relief from its ore tenus unsealing order to remain consistent with its treatment of other Non-Party Does who continue to experience trauma as a result of the events that are…

gov.uscourts.nysd.447706.1137.15_2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1137.15_2 41 pg

…ofPage 01/21/2015 41 2 of 40 sworn affidavit (attached as Exhibit 1) that all her allegations are true – an affidavit consistent with compelling corroborating evidence. BACKGROUND AND COURSE OF PROCEEDINGS Because this case …

gov.uscourts.nysd.447706.980.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.980.0 10 pg

…respectfully write to ask this Court to protect those non-party interests; a request that is consistent with long-standing Circuit precedent establishing that this responsibility “rests heavily upon the shoulders” of the district court. In re New York Times…

gov.uscourts.nysd.447706.132.1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.132.1 31 pg

…make SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 Case 1:15-cv-07433-LAP Document 132-1 Filed 05/01/16 Page 16 of 31 15 G4LMGIUC 1 her story consistent with her previous stories. She has 2…

gov.uscourts.nysd.447706.1247.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1247.0 25 pg

…There, the court recognized that a non-party’s privacy interest should be protected “if this can be done in a manner consistent with the public’s reasonable interest in access to evidence relating to Plaintiffs’ equal protection claim.” Id…

gov.uscourts.nysd.447706.276.0_1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.276.0_1 35 pg

…which is why courts who have looked 14 at this issue have consistently rejected these broad subpoenas. 15 Defendants know that they are not entitled to every 16 single personal email plaintiff has ever sent or ever received 17 in…

gov.uscourts.nysd.447706.235.1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.235.1 31 pg

…make SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 Case 1:15-cv-07433-LAP Document 235-1 Filed 06/21/16 Page 16 of 31 15 G4LMGIUC 1 her story consistent with her previous stories. …

gov.uscourts.nysd.447706.136.0_2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.136.0_2 29 pg

…make SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 G4LMGIUC Case 1:15-cv-07433-LAP Document 136 Filed 05/03/16 Page 15 of 29 15 1 her story consistent with her previous stories. She has 2 claimed…

gov.uscourts.nysd.447706.1307.4.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1307.4 28 pg

…including one named “Virginia.” Id. at 21. It is anticipated that he will testify consistently with that previous testimony. 3 As explained above, as of today, Defendant’s counsel sent an email refusing to attend this deposition set for Tuesday…

gov.uscourts.nysd.447706.1320.10.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1320.10 28 pg

…including one named “Virginia.” Id. at 21. It is anticipated that he will testify consistently with that previous testimony. 3 As explained above, as of today, Defendant’s counsel sent an email refusing to attend this deposition set for Tuesday…

gov.uscourts.nysd.447706.1137.12_2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1137.12_2 28 pg

…including one named "Virginia." Id. at 21. It is anticipated that he will testify consistently with that previous testimony. 3 As explained above, as of today, Defendant's coW1sel sent an email refusing to attend this deposition set for Tuesday…

1320-10.pdf PDF

giuffre-maxwell 1320-10 28 pg

…including one named “Virginia.” Id. at 21. It is anticipated that he will testify consistently with that previous testimony. 3 As explained above, as of today, Defendant’s counsel sent an email refusing to attend this deposition set for Tuesday…

gov.uscourts.nysd.447706.172.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.172.0 28 pg

…including one named “Virginia.” Id. at 21. It is anticipated that he will testify consistently with that previous testimony. 3 As explained above, as of today, Defendant’s counsel sent an email refusing to attend this deposition set for Tuesday…

gov.uscourts.nysd.447706.1320.6.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1320.6 10 pg

…p. 108-111. Defendant’s deposition consisted almost entirely of “I don’t recalls” or “I refuse to answer that question”1 and also included a physical outburst that knocked the court reporter’s computer off the conference room table…

gov.uscourts.nysd.447706.1137.10_2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1137.10_2 10 pg

…2016 De osition of Defendant at p. 108-11 1. Defendant's deP.osition consisted almost entirelY. of "I don't recalls" or "I refuse to answer tha uestion" 1 and also included a hy:sical outburst that knocked the…

1320-6.pdf PDF

giuffre-maxwell 1320-6 10 pg

…p. 108-111. Defendant’s deposition consisted almost entirely of “I don’t recalls” or “I refuse to answer that question”1 and also included a physical outburst that knocked the court reporter’s computer off the conference room table…

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