…2 of 20 TABLE OF CONTENTS PRELIMINARY STATEMENT .................................................................................................1 ARGUMENT ..............................................................................................................................3 I.…
…Maxwell objected to the second deposition, based in part on her privacy concerns about testifying to her adult consensual activity (id.); • Judge Sweet overruled Ms. Maxwell’s objections to the deposition, ruling that her “privacy concerns are alleviated by the…
…2016 that Ms. Maxwell must sit for a second deposition on eight topics all “relating to [her] own sexual activity” and “her knowledge of the sexual activity of others.” (DE 316-6 at 10) Judge Sweet overruled Ms. Maxwell’s…
…When Ms. Maxwell demonstrated that the “investigative privilege” did not exist, Plaintiff threw up the inapplicable “public interest” privilege, the assertion of which was overruled by the Court on April 21, 2016. The Court Ordered: “The criminal investigation. Any materials…
…privilege in these circumstances would result in nothing more than the concealment of the truth. Plaintiffs’ objections on the basis of the attorney-client privilege should be overruled. 2. Plaintiffs Have Waived Their Right To Rely On The Work Product…
…1247 at 20, Plaintiff only addresses Does 28, 97 and 144’s replies. The Court should overrule their objections.1 In its April 19, 2022, ruling concerning the first set of Non-Party Objectors, the Court ordered that certain documents…
…2016). Plaintiff objected to this interrogatory on the ground it requested pre-1999 medical information in “violat[ion]” of the Court’s ruling. The objection should be overruled. The issue 4 Plaintiff’s voluminous arguments and argumentative citations to case…
…should . . . be unsealed if and when the Court overrules Maxwell’s forthcoming objections” for the next set of motions. (See Nov. 10 Letter at 2.) Defendant contends otherwise, reasoning that failure to file an Objection does not result in the…
…s objections should suffice. 14 Case 1:15-cv-07433-LAP Document 1156 Filed 11/19/20 Page 19 of 19 CONCLUSION For the foregoing reasons, the Court should overrule Maxwell’s objections as to Docket Entries 231, 279…
…be unsealed now will reduce the need to revisit documents already partially unsealed and will streamline the unsealing process (likely by years). CONCLUSION For the foregoing reasons, the Court should overrule Maxwell’s objections as to Docket Entries 345, 356…
…names of all Non-Parties whose deadlines to object have passed, and who failed to file an objection, should therefore be unsealed if and when the Court overrules Maxwell’s forthcoming objections. Sincerely, /s/ Sigrid McCawley …