…L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S MOTION TO EXCLUDE DEFENDANT’S DESIGNATION OF DEPOSITION EXCERPTS OF VIRIGINA GIUFFRE IN AN UNRELATED CASE …
…extension of time to respond to "Plaintiffs Motion to Exclude Designation of Deposition Excerpts of Alan Dershowitz in an Unrelated Case" (ECF 561) and "Plaintiffs Motion to Exclude Defendant's Designation of Deposition Excerpts of Virginia Giuffre in an Unrelated…
…of a Protective Order in this case, but does oppose a Protective Order in the form proposed by Defendant because it is overly broad and can lead to abuse and over designation of material as “confidential.” Ms. Giuffre’s proposal1…
…HAS WAIVED ANY ARGUMENT AS TO CONFIDENTIALITY ................ 9 A. Plaintiff Failed to Timely Move this Court to Uphold Her Designation of the Documents as Confidential ................................................................................................................. 9 B. Plaintiff’s Counsel Has …
…seek to overturn the protective order as follows: “The Protective Order states that parties can object to the confidentiality designations: “A party may object to the designation of particular CONFIDENTIAL INFORMATION by giving written notice to the party designating the…
…all Formatted: Font: 12 pt, Font color: Black Formatted: Indent: First line: 0.5", Space disclosures during discovery. Designations under this Order shall be made sparingly, with care, Before: 0 pt, Line spac…
…review the designated testimony in light 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…
…be placed near the Bates number. 8. Designation of a document as CONFIDENTIAL INFORMATION shall constitute a representation that such document has been reviewed by an attorney for the designating party, that there is a valid and good faith basis…
…Giuffre, Plaintiff, Case No: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ____________________________/ PLAINTIFF’S OBJECTIONS TO DEFENDANT’S DEPOSITION DESIGNATIONS AND PLAINTIFF’S CROSS DESIGNATIONS Plaintiff Virginia Giuffre…
…2017 ; replies: February 10, 2017; Initial designation of deposition testimony to be used at trial shall be made by January 13, 2017 ; Objections to deposition designations shall be filed by January 27, 2017; Counter-designations to initial deposition designations shall…
…2016. It states: “Designation of a document as CONFIDENTIAL INFORMATION shall constitute a representation that such document has been reviewed by an attorney for the designating party, that there is a valid and good 4 Case 1:15-cv…
…HAS WAIVED ANY ARGUMENT AS TO CONFIDENTIALITY ................ 9 A. Plaintiff Failed to Timely Move this Court to Uphold Her Designation of the Documents as Confidential ................................................................................................................. 9 B. Plaintiff’s Counsel Has …
…of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------X ............................................... VIRGINIA L. GIUFFRE, Plaintiff, v. …
…just such a reservoir for her profit motives. IV. Category 4: Trial deposition designations and counter-designations. The parties designated and counter-designated many hundreds of pages from deposition transcripts. Such designations are made routinely under Rule 32(a)(6…
…Mar. 30, 2018) (“[A] ‘Confidential’ designation made pursuant to a protective order does not by itself overcome the presumption of public access once the document containing the designation becomes a judicial document.”). Finally, whether the document in question is already…
…A. The Protective Order included a mechanism for one party to challenge another party’s confidentiality designation (such a challenge never occurred) and provided that it did not apply to any information or material disclosed at trial. (Because the case…
…30, 2018) (“[A] ‘Confidential’ designation made pursuant to a protective order does not by itself overcome the presumption of public access once the document containing the designation becomes a judicial document.”). Finally, whether the document in question is already public…
…and deponents reasonably relied on protective order); DE 1062 at 3-6 (protective order tracks permissible scope under Rule 26(c)(1), includes provisions to challenge improper designation of confidentiality, contained no temporal limit, and appropriately limited use of confidential…
…Rotger, 2018 WL 11214575, at *1 (“[A] ‘Confidential’ designation made pursuant to a protective order does not by itself overcome the presumption of public access once the document containing the designation becomes a judicial document.”). Doe 151’s belief in…
…30, 2018) (“[A] ‘Confidential’ designation made pursuant to a protective order does not by itself overcome the presumption of public access once the document containing the designation becomes a judicial document.”). Docket Entry 362 and its related documents should be…
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