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gov.uscourts.nysd.447706.509.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.509.0 18 pg
P17 V11 V9 V12 D8

…the initiation of the litigation, or is willfully and improperly withholding it from production in the matter. LEGAL STANDARD Each litigant has an obligation to take reasonable measures to preserve all potentially relevant documents. That obligation arises even pre-suit…

gov.uscourts.nysd.447706.829.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.829.0 4 pg
P17 V9 D5 V16 D8

…designate as confidential all videotaped depositions and other recordings, and noting that Rule 26(c) standard of good cause “ordinarily requires a party to show that disclosure will result in a clearly defined, specific and serious injury. Broad allegations of…

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