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gov.uscourts.nysd.447706.562.2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.562.2 29 pg

…it is well-recognized that the non-moving party faced with a summary judgment motion supported by appropriate proof may not rely on bare, conclusory assertions found in the pleadings to create an issue and thus avoid summary judgment. Instead…

gov.uscourts.nysd.447706.17.1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.17.1 13 pg

P17 D6 P18 P19 V16

…considered to be within the relevant time frame if it refers or relates to communications, meetings or other events or documents that occurred or were created within that time frame, regardless of the date of creation of the responsive Document. …

gov.uscourts.nysd.447706.562.2.pdf PDF

gov.uscourts.nysd.447706.17.1.pdf PDF

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