…2) specifically requested a telephone conference on the issue of search terms pursuant to the Court’s Order and prior to any such search. Your representation to the Court that we are running “secret search terms unilaterally chosen by Defendant…
…iCloud, one on live.com, and one on hotmail.com during the relevant time periods. Plaintiff’s counsel confesses that prior to being confronted on the issue, they never reviewed the emails in the accounts for relevant information. Menninger Decl.…
…discussion, defense counsel was blindsided when they received the Motion for Sanctions, anticipating that they would soon be receiving a substantially limited and modified list of proposed search terms to permit search and production prior to the July 22 deposition…
…always maintained, that all non-privileged relevant and responsive documents in her possession, custody and control had already been searched for and produced prior to the excessive and redundant briefing on these issues, resulting in no additional production. Plaintiff’s…
…discussion, defense counsel was blindsided when they received the Motion for Sanctions, anticipating that they would soon be receiving a substantially limited and modified list of proposed search terms to permit search and production prior to the July 22 deposition…
…Therefore, both of these documents are highly relevant. Whatever Defendant argues about her prior deposition, she cannot claim that she was questioned about these two emails. Ms. Giuffre deserves the opportunity to ask Defendant about them. II. ARGUMENT A. Discovery…
…counsel for the parties cannot complete their conferral process by tomorrow, March 16, 2016, when the Responses and Objections are due. The undersigned counsel will withdraw the instant motion should counsel for the parties reach an agreement prior to adjudication. …
…to invent stories regarding Alan Dershowitz Churcher’s direct involvement in creating the allegations in the Joinder Motion regarding Plaintiff’s alleged sexual interactions with Alan Dershowitz – or even the knowledge of Alan Dershowitz’ name – is even more apparent. Prior…
…Apr. 8, 2010) (deciding request to seal motion papers prior to ruling on underlying motion). If an undecided motion were deemed a non-judicial document merely because it had not yet been decided, then a court could never deem a…
…because they are not “a more practical method of obtaining the information sought than a request for production or a deposition,” and because they were served in advance of the period “30 days prior to the discovery cut-off date.” …
…object to the unsealing of documents that contain their statements or testimony in this matter, but they object to the release of their names for privacy concerns. Doe 1 and Doe 2 chose to make that limited objection prior to…
…discussion, defense counsel was blindsided when they received the Motion for Sanctions, anticipating that they would soon be receiving a substantially limited and modified list of proposed search terms to permit search and production prior to the July 22 deposition…
…because they are not “a more practical method of obtaining the information sought than a request for production or a deposition,” and because they were served in advance of the period “30 days prior to the discovery cut-off date.” …
…Defendant had the opportunity to propose this language to Plaintiff prior to submitting the form Notice to the Court, but failed to do so. This last-minute injection of language that is clearly intended to scare non-parties into filing…
…practical method of obtaining the information sought than a request for production or a deposition,” and because they were served in advance of the period “30 days prior to the discovery cut-off date.” Local Civil Rule 33.3(b)…
…Maxwell’s willingness to describe the nature of her search, a forensic examination is unnecessary. Lastly, Ms. Maxwell’s representation that “prior to this litigation” she has long had a practice of deleting emails after they have been read does…
…email, formulated without access to the excerpts concerning them, does not make clear what their position is or why. It seems to misapprehend the process because the objection (and non-objection) was lodged prior to receipt of the excerpts. Moreover…
…practical method of obtaining the information sought than a request for production or a deposition,” and because they were served in advance of the period “30 days prior to the discovery cut-off date.” Local Civil Rule 33.3(b)…
…2) specifically requested a telephone conference on the issue of search terms pursuant to the Court’s Order and prior to any such search. Your representation to the Court that we are running “secret search terms unilaterally chosen by Defendant…
…because they are not “a more practical method of obtaining the information sought than a request for production or a deposition,” and because they were served in advance of the period “30 days prior to the discovery cut-off date.” …
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