gov.uscourts.nysd.447706.49.0.pdf PDF
…1990) ................................................. 3 iii INTRODUCTION Plaintiff’s response to a routine request for a plain vanilla protective order is both disturbing and revealing. It is disturbing beca…
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gov.uscourts.nysd.447706.1201.20.pdf PDF
…the basis o f relevant and non - specious factual support . Court intervention should not be invoked to resolve routine discovery matters on the basis of a supposition of bad faith. Further filing of frivolous or vexatious motions lacking sufficient factual…
gov.uscourts.nysd.447706.1219.43.pdf PDF
…Br. at 3). But such a routine search is merely Defendant’s basic obligation under Rule 26 and Rule 34. Ms. Giuffre should not have been forced to seek a Court Order to get such obviously relevant materials from Defendant…
gov.uscourts.nysd.447706.406.0.pdf PDF
…Second, the law throughout the country is clear that routine, raw discovery materials submitted as exhibits to non-dispositive discovery motions do not convert into “judicial documents” and trigger a right of public access. The Court should find that these…
gov.uscourts.nysd.447706.992.0.pdf PDF
…presumption applies here with full force. Category 8: Case Management Documents. It is unclear why documents relating to routine case management issues were ever sealed at all, or what facts could possibly justify their Case 1:15-cv-07433…
gov.uscourts.nysd.447706.218.0.pdf PDF
…in original). See also O’Neill, 71 N.Y.2d at 526-27 (“[A]ttempts to obtain evidence by subjecting the press to discovery as a nonparty would be widespread if not restricted on a routine basis.”). Thus, in order…
gov.uscourts.nysd.447706.996.0.pdf PDF
…counter-designated many hundreds of pages from deposition transcripts. Such designations are made routinely under Rule 32(a)(6) in virtually every trial in which out-of-state witnesses are deposed. They give notice to the other party that the…
gov.uscourts.nysd.447706.1240.0.pdf PDF
…override the public right of access to judicial documents. For this reason, courts in this Circuit have routinely ordered unsealing of documents even though the parties in those cases had agreed to protective orders or confidentiality provisions. See, e.g.…
gov.uscourts.nysd.447706.949.0.pdf PDF
…on the record. I'm not asking this Court to do 23 that, but in Florida where I practice more, most of the time, 24 judges routinely allow me to participate in in-camera 25 examinations -- videos, documents, hearings, testimony …
gov.uscourts.nysd.447706.1028.0.pdf PDF
…an evidentiary hearing, subject to this Court’s discretion whether to grant it. Litigants shouldering an evidentiary burden routinely have the right to request an evidentiary hearing, subject to the court’s discretion whether to grant it. This proceeding should…
gov.uscourts.nysd.447706.980.0.pdf PDF
…years ago. And, critically, such allegations will never be resolved here in light of the parties’ settlement. Courts routinely protect the identities of non-parties who are subject to unproven allegations of impropriety. See, e.g., Nixon v. Warner …
gov.uscourts.nysd.447706.1332.10.pdf PDF
…Also, Dershowitz's now official 12 joining of this motion shows that both directly and by proxy 13 are acting to ratify Dershowitz's private spite. 14 Courts in this district and others routinely seal 15 summary judgment materials, such…
gov.uscourts.nysd.447706.22.0.pdf PDF
…in various countries, the costs and burden of discovery will be extremely high. When facing such “mountains” of discovery, courts routinely grant a motion to stay pending the outcome of a dispositive motion.3 Johnson v. N.Y.U. Sch…
gov.uscourts.nysd.447706.370.0.pdf PDF
…the same principle. Courts have routinely held that because the defendant’s financial condition as it relates to a claim for punitive damages can only proceed upon a determination of liability and special verdict permitting punitive damages, discovery on defendant…
gov.uscourts.nysd.447706.1200.20.pdf PDF
…these “notices” occurred only after careful investigation of the record. This “Notice of Filing Supplemental Authority” is properly construed as a motion for leave to file a sur reply, which is routinely denied by this court. Moreover, such a motion…
gov.uscourts.nysd.447706.936.0.pdf PDF
…HAS THE RIGHT TO INTERVENE AS A NEWS ORGANIZATION Under the law of this Circuit, news organizations are routinely permitted to intervene and be heard on issues involving public access to proceedings and documents, including challenges to discovery protective orders…
gov.uscourts.nysd.447706.1219.19.pdf PDF
…the same principle. Courts have routinely held that because the defendant’s financial condition as it relates to a claim for punitive damages can only proceed upon a determination of liability and special verdict permitting punitive damages, discovery on defendant…
gov.uscourts.nysd.447706.589.0.pdf PDF
…not only entered but repeatedly reaffirmed. D. Cernovich’s Attempt to Make a Distinction About Summary Judgment Materials Also Fails Courts routinely maintain the seal over materials for which confidentiality is important, including summary judgment materials. See Louis Vuitton Malletier…
gov.uscourts.nysd.447706.702.0.pdf PDF
…Also, Dershowitz's now official 12 joining of this motion shows that both directly and by proxy 13 are acting to ratify Dershowitz's private spite. 14 Courts in this district and others routinely seal 15 summary judgment materials, such…
gov.uscourts.nysd.447706.1155.0_2.pdf PDF
…override the public right of access to judicial documents. For this reason, courts in this Circuit have routinely ordered unsealing of documents even though the parties in those cases had agreed to protective orders or confidentiality provisions. See, e.g.…
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