…and thus counter to law. Courts in this Circuit strongly disfavor attempts by collateral litigants to modify protective orders entered in other cases. The Second Circuit has held that where there has been reasonable reliance by a party or non…
…The Court is well aware of many other civil cases where the parties have taken far more than ten depositions by mutual agreement. Defendant’s refusal to agree to a few more depositions here is simply an effort to keep…
…Giuffre has been involved, either as a witness or a party, in three other civil cases relating to the sexual abuse she suffered as a child. Therefore, Defendant’s Requests for Production intentionally target a high volume of privileged documents…
…Pansy, 23 F.3d at 782). The Amodeo I court cited two other Third Circuit cases confirming that circuit’s litmus-test approach to identifying judicial documents: Bank of America National Trust and Savings Association v. Hotel Rittenhouse Association, 800…
…titled, M10- 468- In re Pilot Project Regarding Case Management Techniques for Complex Civil Cases in the Southern District of New York. Pl’s Motion at 9. On the other hand, in her Opposition to Defendant’s Motion to Stay…
…this version of the brief for increased accuracy. There are no other changes. Case 1:15-cv-07433-LAP Document 1198-12 Filed 01/27/21 Page 2 of 30 TABLE OF CONTENTS …
…of 2 JS 44C/S DNY CIVIL COVER SHEET REV 4/2014 The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as reqwred by law…
…issue as a Second Motion for Adverse Inference Instruction, or as whatever other style the Court may suggest. 1 Case 1:15-cv-07433-LAP Document 375 Filed 08/17/16 Page 2 of 4 Aurora Loan Services, LLC…
…subjects covered by the emails. Moreover, despite having access to other email communications that are similar in nature and substance to the two email communications Plaintiff now claims are “key” documents, Plaintiff elected to not examine Ms. Maxwell on those …
…force to all federal civil cases, regardless of the subject matter. In addition to the requirements stated plainly in Fed. R. Civ. P. 26, and in addition to case law from the this Court and others courts within the Southern…
…R. Civ. P., which provides “a party may serve on any other party no more than 25 interrogatories, including all discrete subparts” – in that Defendant has served a total of 59 interrogatories in this case, including subparts, in violation of…
…AND DURING THE DEFENSE CASE........................................3 CONCLUSION............................................................................................................................... 5 i Case 1:15-cv-07433-LAP Document 563 Filed 01/27/17 …
…order to the defendant(s) on or before the completion of discovery. The parties are advised that this Court is participating in a Pilot Program for initial discovery protocols for employment cases alleging adverse action. See www.fjc.gov. 3…
…ii PRELIMINARY STATEMENT .................................................................................................... 1 CERTIFICATE OF SERVICE ..................................................................................................... 17 i Case …
…and communications re defense/common other 125 Present and representation advice and representation evidence. interest Withheld cases Case 1:15-cv-07433-LAP Document 156-…
…261 A.D.2d 34, 39-40 (1st Dep’t 1999) (dismissing defamation complaint for, among other things, failing to specify the actual defamatory words). The only actual words attributed to Ms. Maxwell in the Complaint are: “against Ghislaine Maxwell…
…have cited 7 that in your other opinions with respect to nonparties, they 8 have not set forth a sufficient or compelling basis for the 9 need for these documents. There will be discovery in Judge 10 Koeltl's cases…
…family members and others who were deposed in Maxwell gave testimony likely to undermine Plaintiff’s credibility here. Likewise, 1 Todd & Weld LLP will handle these matters for Dershowitz in both cases. Todd & Weld LLP • Attorneys at Law • One Federal…
…obviously, which 18 poses an approach dealing with the non-parties. One other 19 piece of that, if it would be beneficial to the Court, we have 20 also gone through and categorized the individual non-parties to 21 put…
…more than 15 treatment providers, including ones known specifically to Plaintiff’s counsel and other doctors Plaintiff clearly knew of because she had seen just them days earlier. Plaintiff’s Response is devoted to (a) extraneous, irrelevant and selective quotations…
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