gov.uscourts.nysd.447706.1296.10.pdf PDF
…for 8 any of those lawyers? 9 A. It's on a pro-bono basis. 10 Q. Do you know what each of 11 those lawyers' normal hourly rates 12 are? 13 A. No. 14 Q. Do you know how…
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gov.uscourts.nysd.447706.1335.7.pdf PDF
…for 8 any of those lawyers? 9 A. It's on a pro-bono basis. 10 Q. Do you know what each of 11 those lawyers' normal hourly rates 12 are? 13 A. No. 14 Q. Do you know how…
gov.uscourts.nysd.447706.1256.16.pdf PDF
…communications with counsel) and her Motion to Compel for Improper Objections. Even then, Defendant’s counsel refused to even take the routine step of looking at Defendant’s email and other electronic documents to find responsive documents, but produced, instead…
gov.uscourts.nysd.447706.1325.7.pdf PDF
…communications with counsel) and her Motion to Compel for Improper Objections. Even then, Defendant’s counsel refused to even take the routine step of looking at Defendant’s email and other electronic documents to find responsive documents, but produced, instead…
gov.uscourts.nysd.447706.1198.5_2.pdf PDF
…communications with counsel) and her Motion to Compel for Improper Objections. Even then, Defendant’s counsel refused to even take the routine step of looking at Defendant’s email and other electronic documents to find responsive documents, but produced, instead…
gov.uscourts.nysd.447706.1256.19.pdf PDF
…communications with counsel) and her Motion to Compel for Improper Objections. Even then, Defendant’s counsel refused to even take the routine step of looking at Defendant’s email and other electronic documents to find responsive documents, but produced, instead…
gov.uscourts.nysd.447706.1198.12_3.pdf PDF
…communications with counsel) and her Motion to Compel for Improper Objections. Even then, Defendant’s counsel refused to even take the routine step of looking at Defendant’s email and other electronic documents to find responsive documents, but produced, instead…
gov.uscourts.nysd.447706.1325.14.pdf PDF
…communications with counsel) and her Motion to Compel for Improper Objections. Even then, Defendant’s counsel refused to even take the routine step of looking at Defendant’s email and other electronic documents to find responsive documents, but produced, instead…
gov.uscourts.nysd.447706.1327.7.pdf PDF
…did -- do you recall what when 21 you observed the other females giving massages, do 22 you recall what they would dress like? Did they 23 wear scrubs or did they typically wear normal 24 clothes? 25 A. Normal clothes . …
gov.uscourts.nysd.447706.1332.14.pdf PDF
…form the law of this case. That would be difficult for any special master to do effectively. It is far simpler – and fairer – for the normal deposition rules to simply apply. During the deposition, Defendant’s counsel is free to…
gov.uscourts.nysd.447706.1295.10.pdf PDF
… I 20 mean, I know guys can normally cum 21 once or twice a day, but Jeffrey's not 22 a normal person. 23 So, I mean, our rotation 24 changed every day that specific trip 25 we had in…
gov.uscourts.nysd.447706.1050.0.pdf PDF
…wanted 17 to just expound upon it a little bit, is that in the normal 18 case the fact that a document is available on a court database 19 may not then give rise to publication. I would point out…
gov.uscourts.nysd.447706.1219.30.pdf PDF
…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…
gov.uscourts.nysd.447706.1199.1_1.pdf PDF
…2016, deposition. 2 Defendant appears to have acquired these police reports outside of the normal discovery process, as they unequivocally came from non-parties, yet Defendant never served a notice of subpoena on Plaintiff indicating her efforts to acquire these…
gov.uscourts.nysd.447706.1330.16.pdf PDF
…inference. a. Plaintiff Fails to Identify or Prove the Factors Required for Sanctions Based on Alleged Violation of a Court Order Absent from Plaintiff’s motion is the actual legal standard required for imposition of sanctions, and certainly no argument…
gov.uscourts.nysd.447706.1156.0.pdf PDF
…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…
gov.uscourts.nysd.447706.1328.13.pdf PDF
…1n Q She called_you early in the morning? 10 A Yes. 11 A Not early 11 Q Do you remember seeing pictures of naked or 12 Q Normal!Y_you would report to the house between 12 nude females…
gov.uscourts.nysd.447706.1328.12.pdf PDF
…21 A. Palatial. When you walk up, it looks like 22 a normal door to a townhouse, and when you walk 23 in -- I thought there were four floors. I heard 24 there were seven floors. I didn't see…
gov.uscourts.nysd.447706.1259.0.pdf PDF
…Access .............................................................................. 10 2.1.2 The First Amendment Compels Access ................................................................ 12 2.2 Standard for Sealing a Court Record ........................................................................…
gov.uscourts.nysd.447706.41.5.pdf PDF
…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…
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