…to determine something to be 22 confidential, and then it could be challenged later. 23 And then subsequently after, it looked to us from an 24 incomplete view of the record, 35 motions, the Court said that 25 basically the…
…Ex. M. A court may reopen a deposition if the changes to the transcript are made without adequate reasons, or if they are so substantial as to render the transcript incomplete or useless. See Hlinko, 1997 WL 68563, at*1…
…575 Lexington Ave New York, New York 10022 (212) 446-2300 10 Ms. Maxwell’s Privilege Log is also incomplete because she has unilaterally, arbitrarily, and wrongfully withheld production of responsive documents from a great portion…
…2d. 323, 336 (S.D.N.Y. 2010) (absence of “facts to support the inference that [the subject] statement imputed incompetence, incapacity or unfitness in the performance of [her] profession” as a bookkeeper warranted dismissal of defamation per se claim)…
…had some remarkable memory lapses during earlier depositions, feigned incomprehension of common words such as “puppet,” as well as repeatedly requesting that questions be re-asked or clarified, over and over and over again, when the those questions were clear…