gov.uscourts.nysd.447706.1330.17.pdf PDF
…so. 2 Case 1:15-cv-07433-LAP Document 1330-17 Filed 01/05/24 Page 4 of 12 The Motion is untimely and no special circumstance exists, nor have any been claimed, requiring denial of the motion. B…
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gov.uscourts.nysd.447706.1198.13_1.pdf PDF
…This late production occurred despite the fact that Defendant requested all documents relating to communications with or investigations by law enforcement, which Plaintiff claimed she had produced.4 Plaintiff’s pattern of discovery abuses and failure to disclose necessary and…
gov.uscourts.nysd.447706.1198.29_1.pdf PDF
…1993) (applying the New York state physician-patient privilege, and holding that where plaintiff claimed that she suffered emotional distress, defendants did not have “a license to rummage through all aspects of the plaintiff's life in search of a…
gov.uscourts.nysd.447706.1198.12_3.pdf PDF
…added). Additionally, Ms. Giuffre has claimed punitive damages for the defamation per se. “[C]ourts have generally recognized that ... punitive damages are typically not amenable to the type of disclosures contemplated by Rule 26(a)(1)(A)(iii), and have…
gov.uscourts.nysd.447706.269.0.pdf PDF
…and only then, did Plaintiff “provide releases” or “disclose records.” Her claimed lack of memory as to the names of all of her providers “going back decades,” does not excuse her failures. The doctors at issue are ones she had…
gov.uscourts.nysd.447706.199.0.pdf PDF
…Rinaldo Rizzo and related correspondence. Just days before the deposition, however; Defendant’s counsel claimed she did not realize the deposition was proceeding forward despite having received Ms. Giuffre’s Notice of Serving Subpoena the month prior, and asked Ms…