…her deposition. BACKGROUND On February 6, 2017, Defendant served non-party witness Sarah Ransome with a subpoena that included 30 different document requests and set her compliance date for just seven (7) days later on February 13, 2017. In addition…
…declining to construe an email to the Court from Does 1 and 2 as a formal objection to unsealing and giving Does 1 and 2 14 days after service of requested excerpts to file a formal objection to unsealing (dkt…
…protocol. To that end, we propose the following: that paragraph 2(c) be revised to provide 30 days (rather than 14 days) for non-parties to submit a request for excerpts; that the first sentence of paragraph 2(f) be…
…Non-Parties who have no objection to their names being unsealed. Plaintiff suggests that the Original Parties serve the Non-Party Notice on all Non-Parties within 7 days, and that the Original Parties file letters with the Court 21…
…she informed the Court that she had “already sent releases to all of her medical care providers.” The records Plaintiff requested on April 5, and produced mere days before her deposition on May 3, omitted more than 15 treatment providers…
… We were requesting 30 days to 16 complete those depositions to coordinate with their counsel and 17 then coordinate with the defendant's counsel and get those set, 18 and I believe we can do that without altering the Court…
…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…
…anyone about this issue. > > A few weeks ago Jeff told me they had not received search terms and if I remember correctly said that it would take 10 days after receiving the terms to make the complete production…
…of such rulings and then address any unresolved designation objections. The parties expect to submit in the next few days a proposed schedule for hearings on remaining legal issues in this matter and a revised proposed scheduling order in light …
…Plaintiff’s Joinder Motion in the CVRA action (filed by Edwards and Paul Cassell), that immediately preceded the purportedly defamatory denial by Ghislaine Maxwell three days later that forms the statement at issue in this case. In 2013, Plaintiff r …
…assertions contained in .1 (Of 1 Plaintiff now takes the stance that 1 course, Plaintiff’s Joinder Motion was followed three days later by the denial of Ms. Maxwell’s press agent that forms the basis of t…
…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…
…in that manner, Plaintiff should not be permitted to 1 course, Plaintiff’s Joinder Motion was followed three days later by the denial of Ms. Maxwell’s press agent that forms the basis of this defamation action.). While the present…
…her medical care providers.” The records Plaintiff requested on April 5, and produced mere days before her deposition on May 3 Plaintiff’s Response is devoted to (a) extraneous, irrelevant and selective quotations from witnesses who know nothing about her…
…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…
…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…
…is proper at this time because, as of the date of this filing, fact discovery closes in 17 days (although Ms. Giuffre has recently filed a motion for a 30-day extension of the deadline). In order to give the…
…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.…
…have sex with him in exchange for not telling her parents she had failed to go to school that day. Both Plaintiff and her 17-year old boyfriend verified they had had sexual intercourse in the days before the report…
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