gov.uscourts.nysd.447706.1058.4.pdf PDF
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gov.uscourts.nysd.447706.111.2.pdf PDF
…If plaintiff’s counsel wishes to pursue this matter, he can serve a Rule 30(b)(6) Notice on defendant for a corporate representative(s) to respond to these issues, including the custodial sources who were questioned and whose computers…
gov.uscourts.nysd.447706.1320.33.pdf PDF
…party's officer, director, or managing agent—or a witness designated under Rule 30(b)(6) or 31(a)(4)—fails to obey an order to provide or permit discovery, including an order under Rule 26(f),35, or 37…
gov.uscourts.nysd.447706.1198.1_2.pdf PDF
…party's officer, director, or managing agent—or a witness designated under Rule 30(b)(6) or 31(a)(4)—fails to obey an order to provide or permit discovery, including an order under Rule 26(f),35, or 37…
1320-33.pdf PDF
…party's officer, director, or managing agent—or a witness designated under Rule 30(b)(6) or 31(a)(4)—fails to obey an order to provide or permit discovery, including an order under Rule 26(f),35, or 37…
gov.uscourts.nysd.447706.231.0.pdf PDF
…party's officer, director, or managing agent—or a witness designated under Rule 30(b)(6) or 31(a)(4)—fails to obey an order to provide or permit discovery, including an order under Rule 26(f),35, or 37…
gov.uscourts.nysd.447706.541.0.pdf PDF
…opinion. ............................ 18 B. In this Rule 56 proceeding, this Court’s Rule 12(b)(6) opinion does not control the question of law whether the January 2015 statement constitutes nonactionable opinion. ...................................................…
gov.uscourts.nysd.447706.25.0.pdf PDF
…3 II. MS. MAXWELL’S STATEMENTS ARE PROTECTED BY PRIVILEGE .......... 6 A. Qualified Privilege May Form the Basis for a Rule 12(b)(6) Dismissal ............. 6 B. Ms. Maxwell’s Statements Are Protected by the Self-Defense Privilege ........... 7 C…
gov.uscourts.nysd.447706.15.0.pdf PDF
…and in what manner the statements were made and she omitted any special damages or facts establishing defamation per se. Each of these reasons forms a separate and independent basis to dismiss the Complaint pursuant to Rule 12(b)(6)…
gov.uscourts.nysd.447706.1320.24.pdf PDF
…11) Ms. Boylan; and (12) the 30(b)(6) witness for Victims Refuse Silence. 7 Defendant has unilaterally scheduled - without consulting counsel for Ms. Giuffre - at least two of these depositions for days when depositions of Ms. Giuffre’s witnesses…
gov.uscourts.nysd.447706.1137.17_1.pdf PDF
…Churcher; (11 )- -; and (12) the 30(b)(6) witness for Victims Refuse Silence. 7 Defendant has unilaterally scheduled - without consulting counsel for Ms. Giuffre - at least two of these depositions for days when depositions of Ms. Giuffre's witnesses have…
gov.uscourts.nysd.447706.130.0.pdf PDF
…or to employees who assist them, such as law clerks. See New York Code of Judicial Conduct, Canon 3(B)(6), 22 N.Y.C.R.R. § 100.3(B)(6) ” Canon 3(A)(4) of the Code of Conduct…
gov.uscourts.nysd.447706.928.0.pdf PDF
…Sept. 21, 2012) (Sweet, J.) (“A Rule 12(b)(6) motion to dismiss challenges only the face of the pleading. Thus, in deciding such a motion to dismiss, ‘the Court must limit its analysis to the four corners of the…
gov.uscourts.nysd.447706.1137.16_2.pdf PDF
…Chmcher; ; and (12) the 30(b)(6) witness for Victims Refuse Silence. 6 Defendant has unilaterally scheduled - without consulting counsel for Ms. Giuffre - at least two of these depositions for days when depositions of Ms. Giuffre's witnesses have been…
gov.uscourts.nysd.447706.1320.21.pdf PDF
…11) Ms. Boylan; and (12) the 30(b)(6) witness for Victims Refuse Silence. 6 Defendant has unilaterally scheduled - without consulting counsel for Ms. Giuffre - at least two of these depositions for days when depositions of Ms. Giuffre’s witnesses…
gov.uscourts.nysd.447706.20.0.pdf PDF
…not be routinely stayed simply on the basis that a motion to dismiss has been filed;”...“had the Federal Rules contemplated that a motion to dismiss under FRCP 12(b)(6) would [automatically] stay discovery, they would contain a provision.”). …
1320-21.pdf PDF
…11) Ms. Boylan; and (12) the 30(b)(6) witness for Victims Refuse Silence. 6 Defendant has unilaterally scheduled - without consulting counsel for Ms. Giuffre - at least two of these depositions for days when depositions of Ms. Giuffre’s witnesses…
1320-24.pdf PDF
…11) Ms. Boylan; and (12) the 30(b)(6) witness for Victims Refuse Silence. 7 Defendant has unilaterally scheduled - without consulting counsel for Ms. Giuffre - at least two of these depositions for days when depositions of Ms. Giuffre’s witnesses…
gov.uscourts.nysd.447706.22.0.pdf PDF
…Dismiss. First, the Motion to Dismiss presents multiple, independent bases upon which this Court may dismiss the Complaint pursuant to Rule 12(b)(6). Each basis for dismissal is legally well-founded and, with respect to the two independent privileges…
gov.uscourts.nysd.447706.29.1.pdf PDF
…reasons set forth herein, the Court will grant the Motion to Dismiss the Complaint. I. Standard of Review - Rule 12(b)(6) I. Standard of Review - Rule 12(b)(6) Under Rule 12(b)(6), a Complaint must be dismissed…
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