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.447706.1330.16.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.447706.354.0.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.447706.1332.7.pdf PDF
…came forward to Maureen Callahan. I went to – I walked downstairs. I testified that she is walked around -- I have a usual routine that I do. In the morning I went fearful for her life out, I saw the same…
gov.uscourts.nysd.447706.1327.19.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.447706.1256.16.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.447706.1334.1.pdf PDF
…fo1wai-d to Maureen Callahan. I went to - I walked downstairs. I testified that she is walked around -- I have a usual routine that I do. In the morning I went fearful for her life out, I saw the same…
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…
gov.uscourts.nysd.447706.1198.5_2.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.447706.1218.22.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.447706.1256.19.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.447706.992.0.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.447706.1198.12_3.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.447706.33.0.pdf PDF
…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…
gov.uscourts.nysd.447706.1331.4.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.447706.1325.14.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.447706.1332.11.pdf PDF
…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…
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