…direct violation of that Rule because the interrogatories are not “restricted to those seeking names of witnesses with knowledge of information relevant to the subject matter of the action, the computation of each category of damage alleged, and the existence…
…direct violation of that Rule because the interrogatories are not “restricted to those seeking names of witnesses with knowledge of information relevant to the subject matter of the action, the computation of each category of damage alleged, and the existence…
…direct violation of that Rule because the interrogatories are not “restricted to those seeking names of witnesses with knowledge of information relevant to the subject matter of the action, the computation of each category of damage alleged, and the existence…
…AUTHORITIES ...................................................................................................... iii-v PRELIMINARY STATEMENT .....................................................................................................1 FACTUAL AND PROCEDURAL BACKGROUND...................................................................…
…direct violation of that Rule because the interrogatories are not “restricted to those seeking names of witnesses with knowledge of information relevant to the subject matter of the action, the computation of each category of damage alleged, and the existence…
…direct violation of that Rule because the interrogatories are not “restricted to those seeking names of witnesses with knowledge of information relevant to the subject matter of the action, the computation of each category of damage alleged, and the existence…
…Courts Substance or procedure; determinativeness Federal courts sitting in diversity apply state Synopsis substantive law and federal procedur…
…direct violation of that Rule because the interrogatories are not “restricted to those seeking names of witnesses with knowledge of information relevant to the subject matter of the action, the computation of each category of damage alleged, and the existence…
…direct violation of that Rule because the interrogatories are not “restricted to those seeking names of witnesses with knowledge of information relevant to the subject matter of the action, the computation of each category of damage alleged, and the existence…
…permissible to the limited issue of punitive damages, Plaintiff changes tactics claiming the discovery also relates to 1) Ms. Maxwell’s alleged potential sale of assets in this country and 2) Ms. Maxwell’s alleged financial dependence on Mr. Epstein…
…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…
…As the Court will recall, in court pleadings filed December 30, 2014, Ms. Giuffre initially publicly alleged Defendant had sexually abused her. On September 21, 2015, Ms. Giuffre filed her lawsuit against Defendant here in the Southern District of New…
…As the Court will recall, in court pleadings filed December 30, 2014, Ms. Giuffre initially publicly alleged Defendant had sexually abused her. On September 21, 2015, Ms. Giuffre filed her lawsuit against Defendant here in the Southern District of New…
…that Ms. Maxwell had subjected plaintiff to “sex trafficking” while Plaintiff was 15 years old. Plaintiff alleged in her Rule 26(a)(1)(A)(iii) disclosures that she has suffered noneconomic injury of “not less than” $30 million, medical expenses…
…refers the Court to her Memorandum of Law in Support of Motion to Dismiss wherein she argues as grounds for dismissal both that the Complaint has various pleading deficiencies and that the alleged defamatory statements are protected by not one…
…JR., an individual also known as BILL COSBY, Defendant. MEMORANDUM OPINION The very detailed and complete Complaint in this case alleges that by making or causing to be made three very discreet statements: (1) Defendant defamed Plaintiff, (2) Defendant cast…
…Maxwell denied plaintiff’s gratuitously salacious allegations, sued her for “defamation.” During the course of discovery the parties produced or obtained significant information about plaintiff’s alleged sex activities involving dozens of nonparties. While there was no trial and therefore…
…parties, waiving any privilege; 4) documents primarily for the purpose of providing business advice; and 5) documents allegedly subject to an unidentified common interest or joint defense protection. In addition, Plaintiff has failed to furnish an adequate privilege log, making…
…17 A. Viewed In Context, the Statements are Non-Actionable ........................................ 18 B. The Complaint Does Not Allege to Whom, Where or in What Manner the January 3 Statement Was Made ............................................................................................ 22 C. Plaintiff…
…inquiry report. The board, who denied negligence and alleged that the collision had been caused or contributed to by the deceased's own negligence, refused to disclose the report on the ground, as stated in an affidavit sworn on their…
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