…into a non-prosecution agreement with federal authorities. In a 2014 court filing that has since been struck by the court and withdrawn by counsel, Ms. Roberts, who asserts that she was a victim of Epstein, alleged, among other things…
…somewhat lesser than that afforded to dispositive motions, is still substantial. See id. at 53. Doe 133 asserts that there is little to no public value in the documents, as they are, according to Doe 133, untrue and unreliable. Obj…
…shown defamation may recover at least nominal damages,’” and confirming an award of punitive damages) (internal citation omitted). “In assessing the amount of damages to award for defamation, a jury is not limited to compensating the plaintiff for ‘economic’ losses…
…her Response contains additional impropriety. Plaintiff repeatedly asserts that she has produced and disclosed documents but her chart and her arguments neglect to mention that those documents were only sought and produced after the deposition, indeed up to and including…
…defense, it does not have in mind general and ordinary impeachment materials or matters which might arguably bear on the assessment of credibility of witnesses.”). The striking lack of specificity apparent on the face of the Subpoena further demonstrates Ms…
…maliciously discredit” Plaintiff. Compl. ¶ 37. The Complaint does not allege damages in detail. It generically asserts that Plaintiff has suffered “economic damage, psychological pain and suffering, mental anguish and emotional distress, and other direct and consequential damages.” Compl. Count 1 …
…that the court may impose a range of sanctions, including dismissal or judgment by default, preclusion of evidence, imposition of an adverse inference, or assessment of attorneys' fees and costs. Fed.R.Civ.P. 37(b); see Residential Funding Corp…