…million. Despite claiming defamation damages exceeding $80 million, Plaintiff routinely has stonewalled our efforts to obtain basic information about the nature of the alleged defamation and the scope of her alleged damages. Plaintiff’s frustration of our discovery efforts has…
…million. Despite claiming defamation damages exceeding $80 million, Plaintiff routinely has stonewalled our efforts to obtain basic information about the nature of the alleged defamation and the scope of her alleged damages. Plaintiff’s frustration of our discovery efforts has…
…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…
…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…
…That was a 4 out of the month, something like that. This is a 4 routine everyday. Relay instructions to the 5 long time ago so I'm trying to remember the words. 5 housekeepers and the gardeners and the…
… INTRODUCTION For the third time, Defendant attempts to elevate a routine discover dispute into something over which she seeks sanctions, despite the complete lack of a basis for sanctions and a complete lack of case law supporting her request.1…
…on the basis of 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…
…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…
…at *4 (noting that “[i]n camera review is ‘a practice both long-standing and routine in cases involving claims of privilege.”). Defendant’s current attempt to stall discovery is through the submission of improper, sweeping objections alleging overbreadth of…
…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…
…I came forward to 14 Maureen Callahan. I went to -- I 15 walked downstairs. I walked around -- 16 I have a usual routine that I do. In 17 the morning I went out, I saw the same 18 two people…
…No. 09–CV–3312, 2013 WL 1680684, at *4 (noting that “[i]n camera review is ‘a practice both long-standing and routine in cases involving claims of privilege.’ ”) (quoting In re Grand Jury Subpoenas Dated Mar. 19, 2002 & Aug…
…on the basis of 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…
…it did not result in waiver of the privilege because “the routine step of submitting an affidavit is not a waiver of attorney-client protections.” Doc.184 at 19 (emphasis supplied). x “A waiver of the attorney-client privilege occurs…
…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…
…annoyance, embarrassment, oppression or undue burden or expense that justice requires,” and courts routinely enter protective orders to reduce the burden on subpoenaed non-parties to a case, as well as in cases where the discovery sough is irrelevant. See…
…Ex. L ¶ 3. It is therefore precisely the kind of order that courts routinely modify. In re EPDM, 255 F.R.D. at 319 (“Although such blanket protective orders may be useful in expediting the flow of pretrial discovery materials…
…241 (internal quotation marks omitted). Discovery motions and the documents supporting them are routinely filed in courts across the country without sealing and with the understanding that such 20 documents are publicly accessible. And while the relatively recent history of…
…Sept. 25, 1992)) (“[D]iscovery should not be routinely stayed simply on the basis that a motion to dismiss has been filed;”...“had the Federal Rules contemplated that a motion to dismiss under FRCP 12(b)(6) would [automatically] stay…
…search produced no hits in two of the four email accounts is because no emails containing the search terms ever existed in those two email accounts or because before this litigation occurred 21 any such emails had been routinely deleted…
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