…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…
…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…
…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…
…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…
…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…
…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. ...................................................…
…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…
…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)…
…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…
…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…
…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…
…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…
…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…
…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…
…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.”). …
…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…
…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…
…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…
…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…
…for an Order pursuant to Federal Rule of Civil Procedure 12(b)(6) dismissing the Complaint of Plaintiff Virginia Giuffre in its entirety and granting such other and further relief as the Court deems just and proper. Dated: November 30…
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