Found 43 results for “normal routine standard” in 306ms

gov.uscourts.nysd.447706.1325.7.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1325.7 30 pg

…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

giuffre-maxwell gov.uscourts.nysd.447706.1325.14 30 pg

…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

giuffre-maxwell gov.uscourts.nysd.447706.1327.7 9 pg

…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.447706.69.2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.69.2 21 pg

… Alternatively, if Ms. Giuffre is assumed to work until a normal retirement age of 65, or 33.6 years from her age at the beginning of 2015, and based on an annual growth rate of 2.0% and a discount…

gov.uscourts.nysd.447706.1078.1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1078.1 8 pg

…unwarranted and prejudicial pretrial publicity by the Government, its agents, and lawyers for alleged witnesses. Legal Standard More than fifty years ago, warning of the danger of pretrial publicity to fair trials, the Supreme Court directed trial judges to take…

gov.uscourts.nysd.447706.1199.1_1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1199.1_1 13 pg

…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.447706.1296.2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1296.2 17 pg

…defense counsel once again ranged far beyond the normal parameters of objections and gave instructions directly in contravention of this Court’s Order directing Defendant to answer exactly the type of questions posed to her. In light of Defendant’s…

gov.uscourts.nysd.447706.1078.5.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1078.5 161 pg

…and trying to blame these girls for what happened is so contrary to the evidence, is so contrary to people’s normal sense of morality,” Boies said. “I think that’s just going to enrage a jury if she goes…

gov.uscourts.nysd.447706.1320.10.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1320.10 28 pg

…the witnesses to appear via a trial subpoena. Accordingly, Ms. Giuffre seeks leave to take more than the standard ten depositions in this case. At this time, she seeks leave to take seven additional depositions, as articulated below.2 2…

gov.uscourts.nysd.447706.1201.1_1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1201.1_1 17 pg

…defense counsel once again ranged far beyond the normal parameters of objections and gave instructions directly in contravention of this Court’s Order directing Defendant to answer exactly the type of questions posed to her. In light of Defendant’s…

gov.uscourts.nysd.447706.1332.15.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1332.15 11 pg

…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…

gov.uscourts.nysd.447706.1259.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1259.0 17 pg

…Access .............................................................................. 10 2.1.2 The First Amendment Compels Access ................................................................ 12 2.2 Standard for Sealing a Court Record ........................................................................…

gov.uscourts.nysd.447706.1327.26.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1327.26 27 pg

…Id. at 29. She only witnessed masseuses who were her age or older and they wore “normal” clothes. Id. at 31-32. x She never was asked by Epstein or Maxwell to give sexual massages to any of their friends…

gov.uscourts.nysd.447706.68.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.68.0 17 pg

…Computation Of Damages Complies With Rule 26............6 D. Ms. Giuffre Can Base Alleged Lost Income On “The Jobs of Others” – i.e., On Standard Economic Estimation Techniques. ...........................................................8 E. Plaintiff Has Not Refused To Provide Addresses And Te…

gov.uscourts.nysd.447706.1327.5.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1327.5 17 pg

…defense counsel once again ranged far beyond the normal parameters of objections and gave instructions directly in contravention of this Court’s Order directing Defendant to answer exactly the type of questions posed to her. In light of Defendant’s…

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