…No.: 1:15-cv-07433-LAP Dear Judge Preska: Intervenor Michael Cernovich d/b/a Cernovich Media originally sought to intervene and unseal the wholly-redacted summary judgment documents filed by Defendant Ghislaine Maxwell and the subsequent summary judgment documents…
…be run over Defendant’s data. (DE 323). 2 II. DISCUSSION At a minimum, the Court should direct Defendant to run the search terms in the list originally submitted by Ms. Giuffre. More broadly, the Court should grant Ms…
…be run over Defendant’s data. (DE 323). 2 II. DISCUSSION At a minimum, the Court should direct Defendant to run the search terms in the list originally submitted by Ms. Giuffre. More broadly, the Court should grant Ms…
…and Ms. Maxwell later produced, pursuant to this Court’s Order, documents that originally had been withheld pursuant to privilege. As of April 18, Ms. Maxwell’s production of documents responsive to Plaintiff’s First Request for Production of Documents…
…Docket Entries 143, 164, 172, 199, and 230 (or “the first five motions”), Maxwell has illustrated the very problem that Plaintiff pointed out in the Original Parties’ April 30, 2020 joint letter to the Court. See ECF No. 1052. Because …
…a formal objection to unsealing. The original parties to this action may file their own objection to unsealing no later than (1) 7 days after service of any formal objection by Does 1 and 2, as provided by Paragraph 2…
…this Court’s Protective Order. 4 Case 1:15-cv-07433-LAP Document 1111 Filed 09/01/20 Page 5 of 14 ‘unduly delay and prejudice the adjudication of the rights of the original parties.’” Bridgeport Harbour Place I…
…a court would go about determining that someone's reputation had already been ‘irreparably’ damaged—i.e., that no new reader could be reached by the freshest libel” (Scalia, J.) (emphasis in original)), vacated on other grounds, 477 U.S…
…documents or other evidentiary material…on which each computation is based, including materials bearing on the nature and extent of injuries suffered.” On March 7, Plaintiff’s counsel indicated her intent to supplement the original disclosures. See id., Ex…
…a court would go about determining that someone's reputation had already been ‘irreparably’ damaged—i.e., that no new reader could be reached by the freshest libel” (Scalia, J.) (emphasis in original)), vacated on other grounds, 477 U.S…
…to Plaintiff’s First Request for Production of Documents to Defendant Ghislaine Maxwell, served on October 27, 2015. The original date by which Ms. Maxwell was to respond to Plaintiff’s First Request for Production is today, November 30, 2015…
…stated, ‘[t]he deposition has always been, and still is, treated as a substitute, a second-best, not to be used when the original is at hand.’” United States v. Int’l Bus. Machines Corp., 90 F.R.D. 377…
…5 Of course, Plaintiff and her counsel are the ones who originally filed their Motion for Joinder in the CVRA litigation making the spurious claims about Ms. Maxwell and then withdrew those pleadings as a part of their settlement with…
…331 U.S. 367, 374 (1947) (“what transpires in the court room is public property”). Although the Court originally ordered that the parties had to seek leave to file under seal (ECF No. 62), Judge Sweet subsequently amended that Order…
…Enforce the Court’s Order, to attempt to obtain another deposition with a stern direction from the Court to the Defendant that she must answer questions during her deposition as originally directed by - this Court. That motion is currently pending…
…significant travel to obtain their deposition, and potentially 6 - requiring service of process through other means. Four other treatment providers – Dr. Geiger, Plaintiff also originally disclosed a Dr. Carol Hayek as a treatment provid…
…15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 3 of 21 II. DISCUSSION At a minimum, the Court should direct Defendant to run the search terms in the list originally submitted by Ms. Giuffre. More broadly…
…significant travel to obtain their deposition, and potentially requiring service of process through other means. Four other treatment providers – Dr. Geiger, 6 Plaintiff also originally disclosed a Dr. Carol Hayek as a treatment provider. However, no information has been provided…
…62). He seeks to restore it. 2.1 The Protective Order Contemplates Confidential Materials Not Being Sealed The Court originally entered a protective order that permitted review of requests to seal under the requirements of the Second Circuit. In the…
…significant travel to obtain their deposition, and potentially 6 - requiring service of process through other means. Four other treatment providers – Dr. Geiger, Plaintiff also originally disclosed a Dr. Carol Hayek as a treatment provid…