…as it applies to Doe 1 and Doe 2’s recent communication and the related deadlines for objecting and responding. After conferral with Plaintiff’s counsel, the parties were unable to reach an agreement. Depending on the Court’s clarification…
…aff’d, 814 F.3d 132 (2d Cir. 2016) (disclosing docket sheets after finding there are no “compelling private interests favoring sealing”). Where a presumption of the highest weight exists, “[t]he Court is required to order disclosure absent compelling…
…in support thereof, would show unto the Court as follows: JURISDICTION AND PARTIES 1. The Attorney General of the United States Virgin Islands (herein after "Virgin Islands") brings this action on behalf of the Plaintiff, Government of the Virgin Islands…
…While Ms. Ransome touts her “robust” production, in fact she produced 18 pages of documents (three after the Motion to Compel was filed), an incomplete copy of one of her old passports, and 150 photographs which were given to her…
…While Ms. Ransome touts her “robust” production, in fact she produced 18 pages of documents (three after the Motion to Compel was filed), an incomplete copy of one of her old passports, and 150 photographs which were given to her…
…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…
…aff’d, 814 F.3d 132 (2d Cir. 2016) (disclosing docket sheets after finding there are no “compelling private interests favoring sealing”). Where a presumption of the highest weight exists, “[t]he Court is required to order disclosure absent compelling…
…22, 2016 order which adjourned the briefing schedule on the Plaintiff’s motion for an adverse inference instruction as directed by the Court: “A briefing schedule and submission date will be set after search terms are determined.” The Plaintiff, without…
…12, 2019 Page 2 District of New York prepared and filed with the court a sealed report of her investigation. Newsday moved to unseal the report. After the court released an edited and redacted copy of the report, Newsday appealed…
…with this Court and immediately offered to make Ms. Ransome available to Defendant for a deposition. After first delaying in taking that deposition, Defendant then made this victim of sex trafficking, who had flown to the United States from Barcelona…
…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…
…with this Court and immediately offered to make Ms. Ransome available to Defendant for a deposition. After first delaying in taking that deposition, Defendant then made this victim of sex trafficking, who had flown to the United States from Barcelona…
…documents, particularly electronic documents, dating back over 16 years. However, Ms. Maxwell, prior to this litigation has long had a practice of deleting emails after they have been read. 17. Ms. Maxwell objects to Instruction Nos. 5, 8, 9, 12…
…Qauning PrMJe,e or Proll!ction. The objection must be served before the earlier oflhe time specified for (A) Informat/oll WithMld. A person withholding subpoenaed information compliance or 14 days after the subpoena h, served. lfan objection is made…
…s deposition). The deposition took place in West Palm Beach, Florida. 8. After Epstein was sworn in, he invoked his Fifth Amendment right on every single substantive question he was asked, except the question asking his name. He was asked…
…the initial unsealing protocol. The Defendant in this case, Ghislaine Maxwell, was convicted after a public trial; classes of victims have litigated public lawsuits against Jeffrey Epstein and his co-conspirators (including against several of his financial institutions); and the…
…not require the production of multiple copies of identical Documents. 21. This Request is deemed to be continuing. If, after producing these Documents, You obtain or become aware of any further information, Documents, things, or information responsive to this Request…
…documents, particularly electronic documents, dating back over 16 years. However, Ms. Maxwell, prior to this litigation has long had a practice of deleting emails after they have been read. 17. Ms. Maxwell objects to Instruction Nos. 5, 8, 9, 12…
…documents or provide testimony. While the LiButti Court was considering an adverse inference during a bench trial, it was cognizant that, after conducting the relevance evaluation, courts would also need to assess the issue of undue prejudice under Fed. R…
…summarise the non-contentious evidence in a broadly chronological way. 7. At midday on 12 December 2005, the day after the incident, Davies Arnold Cooper gave legal advice to Total’s lawyers in Paris. This was forwarded to Total UK …