…Motion to Stay Discovery during the pendency of her Motion to Dismiss. LEGAL STANDARD Rule 26(c) of the Federal Rules of Civil Procedure grants courts broad discretion to stay discovery “for good cause shown.” Spencer Trask Software and Info…
…duly licensed to practice in Florida and before this Court pursuant to this Court’s September 29, 2015 Order granting my Application to Appear Pro Hac Vice. 2. I respectfully submit this Declaration in support of Plaintiff Virginia Giuffre’s…
…“[C]ourts generally will not grant leave to expand the number of depositions until the moving party has exhausted the ten depositions permitted as of right under Rule 30(a)(2)(A) or the number stipulated to by the opposing…
…this Court on June 20, 2016, granted in part and denied in part Plaintiff’s Motion. Specifically, this Court held: Federal Rule of Civil Procedure 26(f)(3)(C) requires the parties to state their views and proposals as to…
…2016 Letter Motion to Compel Defendant to Sit for Her Deposition (DE 63) - Granted (DE 106). Plaintiff’s Motion to Compel Documents Subject to Improper Claim of Privilege (DE 33) - Granted in Part (DE 73). Plaintiff’s Motion…
…695 (S.D.N.Y. 2011) (citation and internal quotation marks omitted). Such motions “are properly granted only if there is a showing of: (1) an intervening change in controlling law; (2) the availability of new evidence; or (3) a…
…hereby files this reply in suppo1i of her Motion to Exceed Presumptive Ten Deposition Limit. The motion should be granted because Ms. Giuffre has shown good cause for needing to exceed the ten deposition limit and in light of recent…
…hereby files this reply in suppo1i of her Motion to Exceed Presumptive Ten Deposition Limit. The motion should be granted because Ms. Giuffre has shown good cause for needing to exceed the ten deposition limit and in light of recent…
…exactly two documents. Ms. Giuffre moved to compel Defendant to produce responsive documents and the Court held a hearing on March 17, 2016. During the hearing, the Court granted in part, Ms. Giuffre’s Motion to Compel. Now, twenty-six…
…hereby files this reply in suppo1i of her Motion to Exceed Presumptive Ten Deposition Limit. The motion should be granted because Ms. Giuffre has shown good cause for needing to exceed the ten deposition limit and in light of recent…
…too, is the information contained therein and how it was acquired. For that reason, this Court should grant Ms. Giuffre’s requests Nos .1-3. Defendant states that the material responsive to Ms. Giuffre’s requests Nos. 2-3 constitute…
…hereby files this reply in support of her Motion to Exceed Presumptive Ten Deposition Limit. The motion should be granted because Ms. Giuffre has shown good cause for needing to exceed the ten deposition limit and in light of recent…
…“[C]ourts generally will not grant leave to expand the number of depositions until the moving party has exhausted the ten depositions permitted as of right under Rule 30(a)(2)(A) or the number stipulated to by the opposing…
…hereby files this reply in support of her Motion to Exceed Presumptive Ten Deposition Limit. The motion should be granted because Ms. Giuffre has shown good cause for needing to exceed the ten deposition limit and in light of recent…
…“[C]ourts generally will not grant leave to expand the number of depositions until the moving party has exhausted the ten depositions permitted as of right under Rule 30(a)(2)(A) or the number stipulated to by the opposing…
…“[C]ourts generally will not grant leave to expand the number of depositions until the moving party has exhausted the ten depositions permitted as of right under Rule 30(a)(2)(A) or the number stipulated to by the opposing…
…too, is the information contained therein and how it was acquired. For that reason, this Court should grant Ms. Giuffre’s requests Nos .1-3. Defendant states that the material responsive to Ms. Giuffre’s requests Nos. 2-3 constitute…
…this Court on June 20, 2016, granted in part and denied in part Plaintiff’s Motion. Specifically, this Court held: Federal Rule of Civil Procedure 26(f)(3)(C) requires the parties to state their views and proposals as to…
…As set forth below, this motion is granted in part and denied in part. 2 . Defendant Ghislaine Maxwell ("Maxwell " ) or ("Defendant " ) has moved to compel Plaintiff to disclose a ll eged on - go in g criminal investigations by law enforcement…
…parties have confirmed that Plaintiff’s deposition has yet to be taken in light of this outstanding discovery dispute. Having reviewed and considered Defendant’s motion to compel [DE 40] and Plaintiff’s opposition [DE 41] the Court is GRANTING…