…at 2. The Reality: Courts routinely seal records concerning underage victims – well beyond replacing their names with initials – and victims do not forego their rights to privacy merely because they have played a role in a civil or criminal case…
…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…
…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…
…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…
… 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…
…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…
…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…
…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…
…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…
…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…
…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…
…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…
…exists for the disputed information to be treated as CONFIDENTIAL. Protective Order at ¶ 11. The Materials are sensitive in nature, and therefore fall squarely into the categories of material over which courts routinely grant protection. C.f. Strategic Growth Intern.…
…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.…
…the materials in this case, and the materials at issue in the instant motion, are sensitive in nature, and therefore fall squarely into the categories of material over which courts routinely grant protection. C.F. Strategic Growth Intern., Inc. v…
…the materials in this case, and the materials at issue in the instant motion, are sensitive in nature, and therefore fall squarely into the categories of material over which courts routinely grant protection. C.F. Strategic Growth Intern., Inc. v…
…or sealing order and provides information in discovery, the information must remain sealed. This is incorrect. First, courts in this Circuit have routinely ordered unsealing of documents in cases with protective orders or confidentiality provisions. See, e.g., Gambale v…
…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…
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