…statements through her agent Ross Gow. The offending defamatory statement was issued on January 3, 2015. As demonstrated by the timeline, discussed above, any documents that Maxwell has from the period from 1999 to the present are highly relevant. Ms…
…15 trial after we argue about all of this. 16 But I think it's important for the Court to understand 17 and put into context first what I will call the Alfredo 18 Rodriguez timeline. 19 By the way…
…but is simply refusing to produce the documents. Therefore, based upon the timeline set forth in the moving papers, Ms. Giuffre respectfully requests that this Court direct Defendant to produce responsive documents from 1999 to the present. Defendant argues that…
…2 (“forced to personally serve the Defendant’s former boyfriend, employer, and co-conspirator”). As the timeline and documents now reveal, however, Plaintiff failed to provide notice to Ms. Maxwell that she was attempting to serve a Rule 45 subpoena…
…155 (S.D.N.Y. 2004) (noting the “district court has discretion with regard to determining the timeliness of a motion to intervene.”). Under Rule 24(a), this Court and others in this Circuit recognize a four-part test for…
…E- Com. Ltd., 880 F.3d 620, 627 (2d Cir. 2018) (internal quotation marks and citation omitted). Timeliness is a “threshold consideration under Rule 24(b).” United States v. Pitney Bowes, Inc., 25 F.3d 66, 74 (2d Cir. 1994…
…eye. 28 The Court should not even reach the substance of Dershowitz’s motion, as he has failed to meet the requirements for permissive intervention, which, as Dershowitz admits, include timeliness. MasterCard Intern. Inc. v. Visa Intern. Service Ass'n…
…eye. 28 The Court should not even reach the substance of Dershowitz’s motion, as he has failed to meet the requirements for permissive intervention, which, as Dershowitz admits, include timeliness. MasterCard Intern. Inc. v. Visa Intern. Service Ass'n…
…45(c)(3)(A) (“On timely motion, the issuing court must quash or modify a subpoena ….” (emphasis added)). Ample authority exists holding that timeliness means within the specified compliance period, so long as that period is of reasonable duration…
…is untrustworthy pursuant to 803(8)(B). To determine trustworthiness, the Court should look to the following four factors: (1) the timeliness of the investigation, (2) the special skill or expertise of the official, (3) whether a hearing was held…
…the Government’s stated “law enforcement interest to protect in its CICO enforcement action currently pending in the Virgin Islands” would permit the intervention “interests” standards to swallow the Martindell rule. The Government gives short shrift to the “timeliness” factor…
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