giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…3
III. SANCTIONS AGAINST MS. MAXWELL NOT WARRANTED, RATHER COSTS
OUGHT TO BE AWARDED TO HER .............................................................................. 7
CONCLUSION ............................................................................................................................. 13
CER…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…the complaint). The blatant nature of the defendant’s failure to participate in
discovery is akin to the conduct for which the Second Circuit has awarded sanctions.
This case turns on whether or not Maxwell defamed Ms. Giuffre when she…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…3
III. SANCTIONS AGAINST MS. MAXWELL NOT WARRANTED, RATHER COSTS
OUGHT TO BE AWARDED TO HER .............................................................................. 7
CONCLUSION ............................................................................................................................. 13
CER…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.25
11 pg
…Civ. P., be stricken;
ii. Ms. Maxwell be awarded the costs of engaging the forensic examiner.
Dated: August 1, 2016.
Respectfully submitted,
/s/ Laura A. Menninger
Laura A…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.12
11 pg
…Civ. P., be stricken;
ii. Ms. Maxwell be awarded the costs of engaging the forensic examiner.
Dated: August 1, 2016.
Respectfully submitted,
/s/ Laura A. Menninger
Laura A…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.1_1
11 pg
…Civ. P., be stricken;
ii. Ms. Maxwell be awarded the costs of engaging the forensic examiner.
Dated: August 1, 2016.
Respectfully submitted,
/s/ Laura A. Menninger
Laura A…
giuffre-maxwell
gov.uscourts.nysd.447706.68.0
17 pg
…Revealingly, the first two cases Defendant
cites in support of her made-up demands are state court cases discussing what type of damages
showing is necessary at trial and in order to be awarded a default judgment.
Importantly, in Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.33
24 pg
…3d 123, 144 (2d Cir. 2010) (same). This list is not exclusive, and
many courts also consider the prejudice to the opposing party in determination of the sanction
that should be awarded. See id. (factors not exclusive); Labib v. 1141…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.31
10 pg
…Hillel awarded (http://www.hillel.org/about/news-views/news-views---
blog/news-and-views/2008/02/08/hillel-honors-wexner-with-annual-renaissance-award) its annual Renaissance Award to
Wexner for giving “critical support and counsel to Hillel.”
Though…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…punitive damages claim. Of course, it is well-settled law that “evidence of a tortfeasor’s wealth
is traditionally admissible as a measure of the amount of punitive damages that should be
awarded.” City of Newport v. Fact Concerts, Inc.…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.16
30 pg
…Giuffre’s document production. This is an improper request. It is
unsurprising that Defendant cannot cite to a single case in which any type of sanctions were
awarded under even remotely similar circumstances. Indeed, the purpose of the various aspects…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.1_2
24 pg
…3d 123, 144 (2d Cir. 2010) (same). This list is not exclusive, and
many courts also consider the prejudice to the opposing party in determination of the sanction
that should be awarded. See id. (factors not exclusive); Labib v. 1141…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…punitive damages claim. Of course, it is well-settled law that “evidence of a tortfeasor’s wealth
is traditionally admissible as a measure of the amount of punitive damages that should be
awarded.” City of Newport v. Fact Concerts, Inc.…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.7
30 pg
…Giuffre’s document production. This is an improper request. It is
unsurprising that Defendant cannot cite to a single case in which any type of sanctions were
awarded under even remotely similar circumstances. Indeed, the purpose of the various aspects…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.5_2
30 pg
…Giuffre’s document production. This is an improper request. It is
unsurprising that Defendant cannot cite to a single case in which any type of sanctions were
awarded under even remotely similar circumstances. Indeed, the purpose of the various aspects…
giuffre-maxwell
gov.uscourts.nysd.447706.881.0
8 pg
…filed a lawsuit? What type of lawsuit?
LARGE JURY AWARDS
Who here believes that there should be a cap or limit on the damages awarded in an injury
lawsuit? What do you believe the cap or limit should be?
…
giuffre-maxwell
1320-33
24 pg
…3d 123, 144 (2d Cir. 2010) (same). This list is not exclusive, and
many courts also consider the prejudice to the opposing party in determination of the sanction
that should be awarded. See id. (factors not exclusive); Labib v. 1141…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.0_2
65 pg
…Civ. P., be stricken;
ii. Ms. Maxwell be awarded the costs of engaging the forensic examiner.
Dated: August 1, 2016.
Respectfully submitted,
/s/ Laura A. Menninger
Laura A…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.19
30 pg
…Giuffre’s document production. This is an improper request. It is
unsurprising that Defendant cannot cite to a single case in which any type of sanctions were
awarded under even remotely similar circumstances. Indeed, the purpose of the various aspects…
giuffre-maxwell
gov.uscourts.nysd.447706.1351.0
32 pg
…“In April 2019—almost six months after the
district court awarded attorney’s fees and over a year after the last
Methodology Order—Plaintiffs moved to enforce the Methodology Orders
and to hold Cigna in contempt and impose sanctions.” Id…
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