…Because Ms. Giuffre has shown the importance of reopening Defendant’s deposition on these several important documents, because Defendant has not offered any substantial countervailing consideration, the Court should allow Ms. Giuffre to question Defendant in a deposition about these…
…That conferral was held on May 9 and May 10. Mr. Edwards offered, for example, to consider whether a verified representation by Plaintiff all of the statements that the media “got wrong” would suffice instead of a re-opened deposition…
…That conferral was held on May 9 and May 10. Mr. Edwards offered, for example, to consider whether a verified representation by Plaintiff all of the statements that the media “got wrong” would suffice instead of a re-opened deposition…
…Maxwell has offered to provide responses to specific questions in writing (despite the fact that discovery has closed) which is the least burdensome and less expensive means of obtaining responses to the limited inquiry proposed regarding the two documents. ARGUMENT…
…none of which are satisfactorily met in the circumstances here. (1) the statement has equivalent circumstantial guarantees of trustworthiness; (2) it is offered as evidence of a material fact; 6 Case 1:15-cv-07433-LAP Document 1331-16…
…fails for the same reasons. CONCLUSION The Orders of a United States District Court Judge should be understandable and enforceable. The language proposed by Plaintiff renders the Protection Order neither. The Protective Order offered by Ms. Maxwell is neutral, understandable…
…2d 291, 292, 684 N.Y.S.2d 443, 444 (1st Dep’t 1996) (“Notwithstanding [subpoenaing party’s] excuses offered to the contrary, no clear and specific showing has been made that the relevant material was unavailable elsewhere.”); Flynn, 235…