…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…
… And so was part of your daily routine to 25 go to your computer and check to see if you had Case 1:15-cv-07433-LAP Document 1219-35 Filed 07/15/21 Page 4 of 5 Page 224…
… 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…
… 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 1330-13 Filed 01/05/24 Page 4 of…
…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…
…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…
…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…
…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…
…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…
…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…
…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…
…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…
…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…
…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…
…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…
…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…
…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…
…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…
…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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