gov.uscourts.nysd.447706.1320.1.pdf PDF
…my self to being part of discovery apparently. I am trying to stay out of litigation and not have to employ lawyers for years as I get lost in US legal nightmare. I stand no legal risk currently on these…
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gov.uscourts.nysd.447706.1330.21.pdf PDF
…my self to being part of discovery apparently. I am trying to stay out of litigation and not have to employ lawyers for years as I get lost in US legal nightmare. I stand no legal risk currently on these…
gov.uscourts.nysd.447706.515.0.pdf PDF
…Plaintiff’s Intentional Destruction of Evidence and states as follows: INTRODUCTION All of Plaintiff’s hyperbole and indignation cannot change the simple fact that Plaintiff willfully and intentionally She then either lost a destroyed …
gov.uscourts.nysd.447706.148.0.pdf PDF
…Avenue Denver, CO 80203 303.831.7364 Case 1:15-cv-07433-LAP Document 148 Filed 05/09/16 Page 2 of 9 INTRODUCTION …
gov.uscourts.nysd.447706.1330.22.pdf PDF
…my self to being part of discovery apparently. I am trying to stay out of litigation and not have to employ lawyers for years as I get lost in US legal nightmare. I stand no legal risk currently on these…
gov.uscourts.nysd.447706.68.0.pdf PDF
…Computation Of Damages Complies With Rule 26............6 D. Ms. Giuffre Can Base Alleged Lost Income On “The Jobs of Others” – i.e., On Standard Economic Estimation Techniques. ...........................................................8 E. Plaintiff Has Not Refused To Provide Addresses And Te…
gov.uscourts.nysd.447706.64.0.pdf PDF
…the Cases of Other People. Accordingly, the Disclosure Violates Rule 26 ............................................................................................................. 5 C. Plaintiff Cannot Base Alleged Lost Income on the Jobs of Others ....................... 6 D. Plaintiff Cannot Refuse to Provid…
gov.uscourts.nysd.447706.1328.4.pdf PDF
…expenses of “not less than” $100,000, and lost earnings of “not less than” $5 million.1 She also has requested punitive damages of $50 million. Despite claiming defamation damages exceeding $80 million, Plaintiff routinely has stonewalled our efforts to…
gov.uscourts.nysd.447706.1295.5.pdf PDF
…as a witness in the CVRA action, her duty to preserve this evidence attached. She then either lost a destroyed a second relevant journal after the commencement of this litigation. The intentional destruction of this evidence, regardless of the motive…
gov.uscourts.nysd.447706.207.0.pdf PDF
…that Ms. Giuffre has lost access to her Hotmail.com account (multiple password 1 Case 1:15-cv-07433-RWS Document 207 Filed 06/13/16 Page 2 of 7 recovery attempts failed due to the aged, non-recoverable…
gov.uscourts.nysd.447706.851.0.pdf PDF
…m sorry, your Honor. I think I lost 9 you there. I apologize. 10 So the allegations in the complaint are that when our 11 client came forward and said she was abused by the defendant 12 and Epstein, the…
gov.uscourts.nysd.447706.232.1.pdf PDF
…You base Your contention that You have suffered as a result of the Alleged Defamation by Ghislaine Maxwell “past and future lost wages and past and future loss of earning capacity and actual earnings – precise amounts yet to be computed…
gov.uscourts.nysd.447706.75.0.pdf PDF
…history at issue. ................................... 18 i Case 1:15-cv-07433-LAP Document 75 Filed 03/31/16 Page 3 of 31 2. Plaintiff’s lost wage claims puts her employment history, educational history and earning capacity at issue. ..…
gov.uscourts.nysd.447706.354.0.pdf PDF
…expenses of “not less than” $100,000, and lost earnings of “not less than” $5 million.1 She also has requested punitive damages of $50 million. Despite claiming defamation damages exceeding $80 million, Plaintiff routinely has stonewalled our efforts to…
gov.uscourts.nysd.447706.35.0.pdf PDF
…P. (“If electronically stored information that should have been preserved in the anticipation or conduct of litigation is lost because a party failed to take reasonable steps to preserve it, and it cannot be restored or replaced through additional discovery…
gov.uscourts.nysd.447706.69.2.pdf PDF
…Ms. Giuffre is in the process of retaining an expert, and will provide further information through expert disclosure. 3. Estimated lost income of $180,000 annually. Present value of $3,461,000 to $5,407,000. a. Computation Analysis i…
gov.uscourts.nysd.447706.132.1.pdf PDF
…0300 Case 1:15-cv-07433-LAP Document 132-1 Filed 05/01/16 Page 16 of 31 15 G4LMGIUC 1 her story consistent with her previous stories. She has 2 claimed $5 million in lost wages, your Honor…
gov.uscourts.nysd.447706.441.0.pdf PDF
…revised herRu le 26 d isclosu res backin J u ne,and is no longer seeking any damages relating to lost employment income.D espite thatfact,M s. Giu ffre continu ed to collectherirrelevantemploymentrecord s based on D efend ant…
gov.uscourts.nysd.447706.1330.2.pdf PDF
…You base Your contention that You have suffered as a result of the Alleged Defamation by Ghislaine Maxwell “past and future lost wages and past and future loss of earning capacity and actual earnings – precise amounts yet to be computed…
gov.uscourts.nysd.447706.1320.18.pdf PDF
…rendition of legal services to the client). Some Florida courts have even recognized serious due process issues could be created by a procedure through which a client lost their privilege without an opportunity to be heard in the proceedings. See…
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