…in this matter requires that, after an objection is made to a confidential designation, the party seeking to protect the designation must file a motion within ten business days of the date of the objection. See D.E. 62 at …
…to intimidate, harass and cause undue burden to a non-party. Indeed, Defendant - just days ago - publicly admitted that his goal of deposing Jane Doe No. 3 has nothing to do with this Florida Defamation Action; rather, he is trying…
…1108.) The Protocol provides that, within 14 days of service of excerpts upon a non-party, the relevant non- party may submit to the Court an “objection” to unsealing which “[states] briefly the reasons for the objection” and “[identifies] any…
… In a hotel. 20 Q. And how long did you spend 21 with Mr. Pottinger on that occasion? 22 A. Two days. 23 Q. How many hours over the two 24 days? 25 A. Gosh, about 16. Highly Confidential…
…Plse reach out to him today + I have already suffered such a terrible and painful loss over the last few days that I can't even see what life after press he'll even looks like - statements that don…
…That rule provides that any motion for reconsideration “shall be served withing fourteen (14) days after the entry of the Court’s determination of the original motion” and “shall” include “a memorandum setting forth concisely the matters or controlling decisions…
…eight (she declined). Plaintiff would also agree to allowing each Party thirty (30) days to file their first brief (extending the default deadlines set forth in sections 2(d) and 2(e) of the Protocol). Plaintiff also believes that the…
…During the hearing, the Court granted in part, Ms. Giuffre’s Motion to Compel. Now, twenty-six (26) days later, Defendant has still failed to produce any additional documents. In contrast, to date, Ms. Giuffre has produced over 4,700…
…the time allotted. We conferred with Plaintiffs’ counsel, who said she would not agree to more than seven additional days. We submit there is good cause for a 30-day extension of time. Of the already-decided motions, there are…
…reconsideration request, we ask that the Court stay any unsealing of the deposition material for at least two business days to give us time to apply to the Second Circuit for a stay of the unsealing order pending appeal. As…
…7 (letter from G. Poe to S. McCawley). On June 12, 2016 (sixteen days after Mr. Weinberg accepted service), counsel for plaintiff for the first time asked Mr. Epstein’s counsel for available deposition dates in June. Given the schedules…
…notice shall identify the information to which the objection is made. If the parties cannot resolve the objection within ten (10) business days after the time the notice is received, it shall be the obligation of the party designating the…
…on Ms. Giuffre to collect, evaluate, and log such communications within thirty days of service of the Requests. Local Civil Rule 26.2(b) requires, inter alia, that when documents sought are withheld on the grounds of privilege, a privilege…
…are incorrect.” DE 1226 at 2. In support of this, we cited Section 2(d) of the Protocol: “Within 7 days of service of any Non-Party Objection and accompanying memorandum, if any, the Original Parties may file an opposition…
…Order. 6. Attached as Exhibit E (filed under seal) are hue and con ect copies of excerpts from the continuous days of deposition of Alfredo Rodriguez on July 29 and August 7, 2009 designated Confidential under the Protective Order multiple…
…as required by local rule. Additionally, discovery closed nearly eight months ago, and trial is 60 days away. Substantively, the Motion to Compel is facially frivolous. It argues Mr. Barden’s declaration effected a waiver of the attorney-client privilege…
…file a certificate of service, stating the date and method of service and identifying the Non-Party by his or her pseudonymous identifier. c. Within 14 days of service of the Non-Party Notice, a Non-Party, identified by his …
…and inconvenience. 6 By agreement of the parties, the time to respond was extended an additional six days because defense counsel was in a jury trial at the time the Court’s Order was handed down. 7 See, e.g.…
…to answer questions at her first and second deposition. And, this Court ordered a third deposition for Defendant wrongful failure to produce relevant documents until just days after her second deposition. Notably, Defendant withheld these documents until that second deposition…
…delete all Discovery, including but not limited to Confidential Information, within 30 days of the expiration of the period for direct appeal from any verdict in the above-captioned case; the period of direct appeal from any order dismissing any…