Found 24 results for “simultaneously” in 144ms

gov.uscourts.nysd.447706.1296.16.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1296.16 2 pg

…order (ECF No. 701-1), be unsealed and/or de-designated—an action that would require modification of the Protective Order in this case —the Court also simultaneously unseal Intervenor’s June 21, 2017 letter and its attachments, and remove…

gov.uscourts.nysd.447706.110.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.110.0 7 pg

…antitrust and copyright law in Spinelli, there is one, simple defamation claim based upon Defendant’s widely-publicized statements.”). A case cannot simultaneously be both simple and complex.1 In deciding Ms. Maxwell’s Motion to Stay Discovery (Doc # 18…

gov.uscourts.nysd.447706.1296.17.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1296.17 16 pg

…confidentiality designation concerning the Ransome deposition—an action that would require modification of the Protective Order in this case —it also simultaneously remove the confidentiality designation from several related emails and attachments that the parties previously designated confidential (RANSOME_000273…

gov.uscourts.nysd.447706.111.2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.111.2 5 pg

…The parties confirmed to the Court that they have simultaneously proceeded with merits and class discovery as directed by the Court at the Initial Conference. Case 1:15-cv-07433-LAPDocument Case 2:13-cv-06329-LDW-AKT Document…

gov.uscourts.nysd.447706.1331.7.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1331.7 21 pg

…Phillip Esplin. She simultaneously files her specific objections to portions of these and other depositions designated by Plaintiff. She further states as follows: INTRODUCTION Plaintiff has filed deposition designations for 14 witnesses for use in her case in chief at…

gov.uscourts.nysd.447706.408.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.408.0 13 pg

…1,500 pages of largely irrelevant materials to the victims (DE 225-1 at 5), while simultaneously submitting 14,825 pages of relevant materials under seal to the Court. The Government claimed that these pages were “privileged” for various reasons,…

gov.uscourts.nysd.447706.1129.0_5.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1129.0_5 2 pg

…Any such remedy would be sought within 24-48 hours, and the conferral between counsel for the parties regarding redactions would occur simultaneously because counsel is fully aware of this Court’s desire not to have any “last- minute disputes.” …

gov.uscourts.nysd.447706.1320.28.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1320.28 32 pg

…Maxwell is filing simultaneously with this Response a Motion to Re-Open Plaintiff’s Deposition. 2 Case 1:15-cv-07433-LAP Document 1320-28 Filed 01/03/24 Page 6 of 32 BACKGROUND To divert attention away from…

gov.uscourts.nysd.447706.1218.49.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1218.49 27 pg

…opposite. 5. In doing so, Mr. Cassell seeks to accomplish two goals simultaneously: first, to suppress information—the Requested Documents—which exculpates me from the charges of sexual misconduct, while allowing Ms. Giuffre and her allies to publicly disseminate those…

gov.uscourts.nysd.447706.1090.4_1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1090.4_1 29 pg

…Through these multiple litigations and representations, they attempt to strategically leverage attorney-client communications and attorney work product to their tactical advantage by selectively disclosing information. Simultaneously, they desperately seek to avoid disclosure of related materials they know are unfavorable…

gov.uscourts.nysd.447706.1256.12.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1256.12 32 pg

…Maxwell is filing simultaneously with this Response a Motion to Re-Open Plaintiff’s Deposition. 2 Case 1:15-cv-07433-LAP Document 1256-12 Filed 05/03/22 Page 6 of 32 Case 1:15-cv-07433-LAP…

gov.uscourts.nysd.447706.164.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.164.0 29 pg

…Through these multiple litigations and representations, they attempt to strategically leverage attorney-client communications and attorney work product to their tactical advantage by selectively disclosing information. Simultaneously, they desperately seek to avoid disclosure of related materials they know are unfavorable…

gov.uscourts.nysd.447706.1330.4.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1330.4 27 pg

…opposite. 5. In doing so, Mr. Cassell seeks to accomplish two goals simultaneously: first, to suppress information—the Requested Documents—which exculpates me from the charges of sexual misconduct, while allowing Ms. Giuffre and her allies to publicly disseminate those…

gov.uscourts.nysd.447706.1218.50.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1218.50 15 pg

…Epstein]’.” Dershowitz Decl., Ex. M at 8 (emphasis added). 1 Case 1:15-cv-07433-LAP Document 1218-50 Filed 07/15/21 Page 6 of 15 simultaneously shielding those documents from public view. The courts are presumptively public…

gov.uscourts.nysd.447706.179.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.179.0 22 pg

…Giuffre to spend time and resources on unnecessary motion practice, while simultaneously wasting judicial resources. The Court should not indulge Defendant’s attempts to imprint the Court’s prior ruling -- addressing a wholly different set of underlying facts -- onto this…

gov.uscourts.nysd.447706.946.0_1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.946.0_1 14 pg

…the problem with such an order: [E]ach party could circumvent the "good cause" standard for protection and simultaneously shift the burden to his adversary to unseal a document while benefitting from the more rigorous "extraordinary circumstances" standard that would…

gov.uscourts.nysd.447706.63.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.63.0 22 pg

…R. CIV. P. 26 As detailed in the simultaneously filed pleading, Plaintiff has failed to properly make disclosures pursuant to Rule 26(a)(1). While these disclosures may not directly impact the subject matter of Defendant’s depositions, they demonstrate…

gov.uscourts.nysd.447706.634.0_2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.634.0_2 15 pg

…for a 7 deposition, and we do not have time going forward to both do 8 that and simultaneously engage in the very complicated, 9 rigorous pretrial depressed schedule that we have set between 10 now and March 13th. If…

gov.uscourts.nysd.447706.1137.15_2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1137.15_2 41 pg

…about 1,500 pages of irrelevant materials to the victims (DE 225-1 at 5), while simultaneously submitting 14,825 pages of relevant materials under seal to the Court. The Government claimed that these pages were “privileged” for various reasons…

1320-28.pdf PDF

giuffre-maxwell 1320-28 32 pg

…Maxwell is filing simultaneously with this Response a Motion to Re-Open Plaintiff’s Deposition. 2 Case 1:15-cv-07433-LAP Document 1320-28 Filed 01/03/24 Page 6 of 32 BACKGROUND To divert attention away from…

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