giuffre-maxwell
gov.uscourts.nysd.447706.375.0
4 pg
…for Adverse Inference Instruction, based on
new, relevant information in the case, namely, Defendant’s behavior and representations that
occurred after Ms. Giuffre filed her July 13, 2016, Motion for an Adverse Inference Instruction
(DE 278). The Motion for Adverse…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…for Adverse Inference Instruction Based on New Information. Eleven
months into this case, and after the close of fact discovery, Defendant continues to refuse to
abide by her most basic and fundamental discovery obligations. A summary of this ongoing and
…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…for Adverse Inference Instruction Based on New Information. Eleven
months into this case, and after the close of fact discovery, Defendant continues to refuse to
abide by her most basic and fundamental discovery obligations. A summary of this ongoing and
…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.19
21 pg
…for Adverse Inference Instruction Based on New Information. Eleven
months into this case, and after the close of fact discovery, Defendant continues to refuse to
abide by her most basic and fundamental discovery obligations. A summary of this ongoing and
…
giuffre-maxwell
gov.uscourts.nysd.447706.308.0
7 pg
… (3) that Ms. Kellen be ordered to pay a civil penalty of $2500 per day for each day after
the day on which her deposition is rescheduled if she fails to appear at that time; and (4) that the
Court…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
… Discovery of Financial Information is Relevant to Show Defendant’s
Transfer of Assets Out of the Jurisdiction after the Commencement of
Litigation and thus Her Consciousness of Guilt.
The requested financial information is relevant to issues relating to Defendant’s…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…After holding that the district court’s
“failure to conduct an individualized review of the sealed materials” was an abuse of discretion,
the Second Circuit in dicta “describe[d] certain methods courts can employ to” prevent records
from being used…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…Civ. 7433 (RWS) (S.D.N.Y. May 3, 2017), ECF No. 892 (Opinion Granting
Cernovich Motion to Intervene). Intervention may be permitted even years after a case has been
administratively closed. Counihan v. Allstate Ins. Co., 907 F. Supp…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 pg
…2015. Nearly a year later, after this Court has
specifically ordered Defendant to produce her responsive email from all her accounts, Defendant
has produced none from this account. Not only has Defendant failed to produce emails from the
account she…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.2_1
10 pg
…captured. However, it is
Ms. Giuffre’s position that such a production - long after the close of fact discovery - would be
untimely and prejudicial. Accordingly, based on Defendant’s systematic foot-dragging and
obstructionism during the entire discovery period, and…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.33
24 pg
…April 21, 2016 hearing, the Court ordered Plaintiff to produce the records from
Ms. Giuffre’s medical doctors (apart from pre-1999) and to respond fully to the interrogatories
concerning all of her treating physicians after 1999. Id. (Tr. 20…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.1_2
24 pg
…April 21, 2016 hearing, the Court ordered Plaintiff to produce the records from
Ms. Giuffre’s medical doctors (apart from pre-1999) and to respond fully to the interrogatories
concerning all of her treating physicians after 1999. Id. (Tr. 20…
giuffre-maxwell
1320-33
24 pg
…April 21, 2016 hearing, the Court ordered Plaintiff to produce the records from
Ms. Giuffre’s medical doctors (apart from pre-1999) and to respond fully to the interrogatories
concerning all of her treating physicians after 1999. Id. (Tr. 20…
giuffre-maxwell
gov.uscourts.nysd.447706.561.0
22 pg
…2001) (deposition of insured would not be
admissible against assignee of insured, which had been added to insurer’s action for rescission after
insured’s deposition was taken, because the insured’s motivations in deposition would not be the
same…
giuffre-maxwell
gov.uscourts.nysd.447706.231.0
23 pg
…April 21, 2016 hearing, the Court ordered Plaintiff to produce the records from
Ms. Giuffre’s medical doctors (apart from pre-1999) and to respond fully to the interrogatories
concerning all of her treating physicians after 1999. Id. (Tr. 20…