giuffre-maxwell
gov.uscourts.nysd.447706.343.0
8 pg
…Giuffre has been diligently attempting to depose
Mr. Gow and it is only because of his obstructionism (apparently coordinated with Defendant) that
his deposition has not been taken. Allowing a short extension of time to permit international
process to be…
giuffre-maxwell
gov.uscourts.nysd.447706.492.0
9 pg
…An English Court has since ordered Gow to sit for his deposition, despite Defendant and her
counsel’s obstructionist refusal to produce him prior to that litigation.
Second, these documents are relevant precisely for the reason Defendant attempts to say…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…pleads guilty on March 18th, 2010, to obstruction of
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 824 Filed 04/03/17 Page 28 of 47 28
H3GVGIUC
1 justice. On the…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…May 27, 2016 e-mail Correspondence from Laura Menninger to
Bradley Edwards. This obstruction of discovery by refusing to attend subpoenaed depositions that were
noticed to her about one month ago on May 4, 2016 should not be condoned. See…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…May 27, 2016 e-mail Correspondence from Laura Menninger to
Bradley Edwards. This obstruction of discovery by refusing to attend subpoenaed depositions that were
noticed to her about one month ago on May 4, 2016 should not be condoned. See…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…May 27, 2016 e-mail Correspondence from Laura Menninger to
Bradley Edwards. This obstruction of discovery by refusing to attend subpoenaed depositions that were
noticed to her about one month ago on May 4, 2016 should not be condoned. See…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.3
28 pg
…May 27, 2016 e-mail Correspondence from Laura Menninger to
Bradley Edwards. This obstruction of discovery by refusing to attend subpoenaed depositions that were
noticed to her about one month ago on May 4, 2016 should not be condoned. See…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.16
10 pg
…his statements. Mr. Rodriguez is a
convicted criminal, and was convicted for obstruction of justice based on the very testimony
Plaintiff seeks to admit. He either created evidence to use in those proceedings, or he hid
evidence in them. Either…
giuffre-maxwell
gov.uscourts.nysd.447706.43.0
15 pg
…participate in and begin the
discovery process. From the moment this case began, it appears that the Defendant’s goal has
been obstruction and delay, with the apparent aim of avoiding discovery altogether. The
Defendant’s opposition brief is the…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.0
9 pg
…subornation of perjury, obstruction of justice and conspiracy. The government:
speculated that the pretrial deposition testimony might be relevant to its
investigation into matters similar to those that had been the subject of the
Martindell action and might be useful…
giuffre-maxwell
1320-10
28 pg
…May 27, 2016 e-mail Correspondence from Laura Menninger to
Bradley Edwards. This obstruction of discovery by refusing to attend subpoenaed depositions that were
noticed to her about one month ago on May 4, 2016 should not be condoned. See…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.7
21 pg
…¶ 8-11. Mr.
Rodriguez subsequently was prosecuted and imprisoned for this bribery and obstruction scheme.
These actions and conviction, which did not occur until after the deposition Plaintiff seeks to
proffer, are quintessential character impeachment evidence that no one has…
giuffre-maxwell
gov.uscourts.nysd.447706.185.8
24 pg
…in pretrial
discovery proceedings, that the matter is privileged.”). As the court in Hearn put it:
In an ordinary case the obstruction is not likely to be great, for attorney-client
communications are usually incidental to the lawsuit, notwithstanding their
…
giuffre-maxwell
gov.uscourts.nysd.447706.172.0
28 pg
…May 27, 2016 e-mail Correspondence from Laura Menninger to
Bradley Edwards. This obstruction of discovery by refusing to attend subpoenaed depositions that were
noticed to her about one month ago on May 4, 2016 should not be condoned. See…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…1993) (internal citations omitted). The Defendant’s
continued systemic foot-dragging and obstructionism – even following the Court’s June 20
Sealed Order and August 10, 2016 Order [DE 352] – makes an adverse inference instruction with
regard to Defendant’s documents…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.33
12 pg
…1993) (internal citations omitted). The Defendant’s
continued systemic foot-dragging and obstructionism – even following the Court’s June 20
Sealed Order and August 10, 2016 Order [DE 352] – makes an adverse inference instruction with
regard to Defendant’s documents…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.2
12 pg
…12
Tr. at 168:18 - 181:24. It appears that Defendant’s misleading tally of questions posed to her
includes all the times questions were repeated or needlessly re-worded due to her obstructionist
deposition tactics.
Indeed, Defendant, who claimed…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…and in light of the
defamation claim in this case, is so unfounded and obstructionist that it constitutes a violation of
this Court’s Order, whether or not Defendant actually engaged in the “extraordinary and
unreasonable” task of running the…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 pg
…1993) (internal citations omitted). The Defendant’s
continued systemic foot-dragging and obstructionism – even following the Court’s June 20
Sealed Order and August 10, 2016 Order [DE 352] – makes an adverse inference instruction with
regard to Defendant’s documents…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…and in light of the
defamation claim in this case, is so unfounded and obstructionist that it constitutes a violation of
this Court’s Order, whether or not Defendant actually engaged in the “extraordinary and
unreasonable” task of running the…
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