Found 99 results for “consistent” in 144ms

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.447706.264.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.264.0 3 pg

…ordered as follows: This matter being subject to a Protective Order, the parties are directed to meet and confer regarding redactions to this Opinion consistent with that Order. The parties are further directed to jointly file a proposed redacted version…

gov.uscourts.nysd.447706.1330.17.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1330.17 12 pg

…30(a)(2)(A)(ii)). “Leave should be granted to the extent that doing so is consistent with the factors set forth in Rule 26(b)(2), such as ‘whether the second deposition of the witness would be unnecessarily cumulative…

gov.uscourts.nysd.447706.995.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.995.0 11 pg

…revealed. The law relating to filing documents under seal is not intended to allow individuals who participated in actionable conduct to prevent the public from knowing their identity. Consistent with the general presumption of public access to court documents, the…

gov.uscourts.nysd.447706.343.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.343.0 8 pg

…in her moving brief. While the conduct of Defendant and Mr. Gow is consistent with the obstructionist tactics Defendant has employed throughout this litigation, the important point at this stage of the case is to secure Mr. Gow’s testimony…

gov.uscourts.nysd.447706.1320.33.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1320.33 24 pg

…Maxwell would require an extension of the discovery period ................................ 17 II. STRIKING CLAIMS FOR MEDICAL AND EMOTIONAL DISTRESS DAMAGES IS CONSISTENT WITH THE PURPOSE OF RULE 37, COMMENSURATE WITH THE INFORMATION WITHHELD, AND LESS HARSH THAN THE AVAILABLE DISMISSAL SANCTION..…

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.447706.639.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.639.0 2 pg

…of the new anticipated trial date of May 15, 2017. Accordingly, the parties request that the Court vacate the hearing scheduled for consistent with the Court's schedule. s February 23, 2017 in this case to be rescheduled by agreement…

gov.uscourts.nysd.447706.1198.1_2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1198.1_2 24 pg

…Maxwell would require an extension of the discovery period ................................ 17 II. STRIKING CLAIMS FOR MEDICAL AND EMOTIONAL DISTRESS DAMAGES IS CONSISTENT WITH THE PURPOSE OF RULE 37, COMMENSURATE WITH THE INFORMATION WITHHELD, AND LESS HARSH THAN THE AVAILABLE DISMISSAL SANCTION..…

gov.uscourts.nysd.447706.1202.8.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1202.8 6 pg

…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…

1320-33.pdf PDF

giuffre-maxwell 1320-33 24 pg

…Maxwell would require an extension of the discovery period ................................ 17 II. STRIKING CLAIMS FOR MEDICAL AND EMOTIONAL DISTRESS DAMAGES IS CONSISTENT WITH THE PURPOSE OF RULE 37, COMMENSURATE WITH THE INFORMATION WITHHELD, AND LESS HARSH THAN THE AVAILABLE DISMISSAL SANCTION..…

gov.uscourts.nysd.447706.1129.0_5.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1129.0_5 2 pg

…and difficult to communicate with) is still considering whether to seek any further emergency appellate remedies and/or to provide this Court additional information to the extent consistent with other courts’ rulings that might impact the release of these materials…

gov.uscourts.nysd.447706.1256.30.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1256.30 6 pg

…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…

gov.uscourts.nysd.447706.961.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.961.0 9 pg

…Ms. Giuffre demonstrates below, Courts within the Second Circuit consistently hold that document destruction obligations under a protective order are not triggered until the completion of all the appellate proceedings. While many aspects of this case are obviously concluded, issues…

gov.uscourts.nysd.447706.231.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.231.0 23 pg

…Maxwell would require an extension of the discovery period ................................ 17 II. STRIKING CLAIMS FOR MEDICAL AND EMOTIONAL DISTRESS DAMAGES IS CONSISTENT WITH THE PURPOSE OF RULE 37, COMMENSURATE WITH THE INFORMATION WITHHELD, AND LESS HARSH THAN THE AVAILABLE DISMISSAL SANCTION..…

gov.uscourts.nysd.447706.1227.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1227.0 2 pg

…1143 at 2. Doe did not object to proceeding this way when Plaintiff filed her letter nine months ago, and the Original Parties have consistently relied on this understanding, which has never been challenged or otherwise contradicted. Finally, even if…

gov.uscourts.nysd.447706.1214.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1214.0 7 pg

…1 ARGUMENT In the Objections, Ms. Maxwell concedes that this Court has consistently found that the presumption of public access outweighs Ms. Maxwell’s asserted countervailing interests, and she fails to offer any additional arguments to warrant the continued sealing…

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.447706.1328.20.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1328.20 14 pg

…A (GM00784- 00801). Consistent with Florida law, the records were redacted by the Palm Beach County Sheriff’s Office for the identities and other identifying information of all juveniles as well as Plaintiff’s parents. x January 1998 – In contradiction…

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