gov.uscourts.nysd.447706.1327.24.pdf PDF
… And so was part of your daily routine to 25 go to your computer and check to see if you had MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1327-24 Filed 01/05/24 Page 4 of…
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gov.uscourts.nysd.447706.1200.18.pdf PDF
…A. My computer in my office. 24 Q. And so was part of your daily routine to 25 go to your computer and check to see if you had Page 224 1 JOHN ALESSI 2 MindSpring messages? 3 A…
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…
gov.uscourts.nysd.447706.1330.16.pdf PDF
…Court and Ms. Maxwell’s time and needlessly multiply these proceedings. Courts in this district routinely deny motions based on failure to confer prior to the motion when such conferral is required by the Rules or Court Order. Prescient Partners…
gov.uscourts.nysd.447706.343.0.pdf PDF
…of Time, and the Southern District of New York Recognizes that Extensions of Time are Proper where Service through the Hague Requires a Foreign Judicial Order Courts routinely grant extensions of time of deadlines when awaiting Hague Convention service, and…
gov.uscourts.nysd.447706.1328.4.pdf PDF
…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…
gov.uscourts.nysd.447706.354.0.pdf PDF
…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…
gov.uscourts.nysd.447706.1332.1.pdf PDF
…what computer would you use? A. My computer in my office. Q. And so was part of your daily routine to go to your computer and check to see if you had MindSpring messages? A. No. That was at the…
gov.uscourts.nysd.447706.1328.41.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.447706.1296.10.pdf PDF
…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…
gov.uscourts.nysd.447706.1200.11_1.pdf PDF
…what computer would you use? A. My computer in my office. Q. And so was part of your daily routine to go to your computer and check to see if you had MindSpring messages? A. No. That was at the…
gov.uscourts.nysd.447706.1335.7.pdf PDF
…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…
gov.uscourts.nysd.447706.1330.11.pdf PDF
…what computer would you use? A. My computer in my office. Q. And so was part of your daily routine to go to your computer and check to see if you had MindSpring messages? A. No. That was at the…
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.447706.1256.16.pdf PDF
…communications with counsel) and her Motion to Compel for Improper Objections. Even then, Defendant’s counsel refused to even take the routine step of looking at Defendant’s email and other electronic documents to find responsive documents, but produced, instead…
gov.uscourts.nysd.447706.1328.18.pdf PDF
… 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…
gov.uscourts.nysd.447706.1327.9.pdf PDF
…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…
gov.uscourts.nysd.447706.43.0.pdf PDF
…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…
gov.uscourts.nysd.447706.1325.7.pdf PDF
…communications with counsel) and her Motion to Compel for Improper Objections. Even then, Defendant’s counsel refused to even take the routine step of looking at Defendant’s email and other electronic documents to find responsive documents, but produced, instead…
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