…the first of 5 compelling need. 6 Secondly, your Honor, especially with regard to the 7 more recent discovery standard related to proportionality, 8 there really is a compelling need for efficiency here, which 9 again, I won't repeat…
…this action. A further Motion to Compel and for sanctions regarding her instransigence is forthcoming. 1 ignores controlling law that obligates her to meet a heightened burden above and beyond typical Rule 26 standards when seeking such broad, sensitive personal…
…2012). There can be no legitimate purpose for the movants seeking pictures of Jane Doe 43 after her attempted suicide and these are documents they can seek through the normal courses of discovery before Judge Koeltl. As with other non…
…4 3 The Protocol provides Non-Parties with notice and the opportunity to object to unsealing as a courtesy that is not provided in the vast majority of cases. In the normal course, nonparties whose names are mentioned in depositions…
…Access .............................................................................. 10 2.1.2 The First Amendment Compels Access ................................................................ 12 2.2 Standard for Sealing a Court Record ........................................................................…
…with the Court in this matter, it shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. Formatted: Normal, Indent: Left: 0.5…
…with the Court in this matter, it shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. Formatted: Normal, Indent: Left: 0.5…
…Access ............................................................................... 4 2.1.2 The First Amendment Compels Access .................................................................. 5 2.2 Standard for Sealing a Court Record .....................................................................…
…interest privilege which shields from disclosure information received by governmental entities where the public interest requires that such communications, or the sources thereof, should be kept confidential and not subject to the normal, liberal discovery rules.” Labarbera v. Ulster Cty…
…Protection of Documents through the Appellate Process Ms. Giuffre’s counsel decision to wait for the conclusion of the three appeals before implementing the document destruction provisions of the protective order is consistent with standard practice. In the November 8…
…be necessary]”; McDonald v. Hammons, 129 F.3d 114 (2d Cir.1997) (the need to disqualify counsel “frequently only becomes clear at the conclusion of the underlying litigation”); Norman Reitman Co. v. IRB–Brasil Resseguros S.A., No. 01 Civ…
…10 2. Plaintiffs Relevancy and Admissibility Objections Discovery requests must be relevant to the subject matter of the litigation and must seek admissible evidence or be reasonab)y calculated to lead to admissible evidence. Davich v. Norman Bros. Nissan, Inc…
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