Found 25 results for “routine” in 203ms

gov.uscourts.nysd.447706.1250.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1250.0 7 pg

…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…

gov.uscourts.nysd.447706.1335.7.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1335.7 469 pg

…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.447706.1219.43.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1219.43 12 pg

…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.447706.1327.9.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1327.9 21 pg

…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.447706.1198.5_2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1198.5_2 30 pg

…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

giuffre-maxwell gov.uscourts.nysd.447706.992.0 5 pg

…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

giuffre-maxwell gov.uscourts.nysd.447706.1198.12_3 30 pg

…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.447706.1295.13.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1295.13 35 pg

…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.447706.1328.9.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1328.9 21 pg

…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.447706.1199.1_1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1199.1_1 13 pg

…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.…

gov.uscourts.nysd.447706.1240.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1240.0 5 pg

…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.447706.1278.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1278.0 4 pg

…prevent manifest injustice”). Courts in this Circuit routinely address these precise concerns by establishing a prompt deadline for a party to seek a further extension of a stay pending appeal without imposing a deadline on the Second Circuit to issue…

gov.uscourts.nysd.447706.1067.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1067.0 10 pg

…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…

gov.uscourts.nysd.447706.1295.11.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1295.11 19 pg

…Ransome Dep.) at 36:25- 43:24. The article details multiple things, including that Mr. Epstein has routinely settled out of court many civil cases brought against him by various women. See Menninger Decl., Ex. B. After reading the article…

gov.uscourts.nysd.447706.1330.15.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1330.15 43 pg

…the party must file a motion, "setting forth a reasonable basis for departing from the general policy of a public filing," and courts in this district routinely grant parties' motions to file under seal for good cause. See e.g…

gov.uscourts.nysd.447706.1028.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1028.0 5 pg

…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…

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