…2) holding that the transcript of Giuffre’s deposition in a separate action, offered by a third-party in support of a motion to intervene in this case, was entitled to no more than a “barely cognizable” presumption of public…
…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…
…signed and the documents have been produced; and 2) there is no prejudice because they have offered to permit the re-deposition of Plaintiff on newly revealed medical providers and belatedly produced documents. The law does not permit a Plaintiff…