…certification. More importantly, Plaintiff, in direct contradiction to both the letter and spirit of Rule 37, did not make any effort to confer with Ms. Maxwell’s counsel regarding any of the issues presented in her Motions to Compel. This…
…her own testimony. For these reasons, Plaintiff’s depositions must be reopened to examine her on newly discovered evidence and her contradictory statements. ARGUMENT “A person who has previously been deposed in a matter may be deposed again, but only…
…Mr. Barton drafted the bulk of the statement. That's not true at all. If the Court looks 18 19 -- at the papers cited by the response, there is no contradiction of Mr. Barton's testimony. Mr. Barton said that…
…Barton drafted the bulk 17 of the statement. That's not true at all. If the Court looks 18 at the papers cited by the response, there is no contradiction 19 of Mr. Barton's testimony. Mr. Barton said that…
…of injuring the plaintiff. One who makes a public attack upon another subjects his own motives to discussion. It is a contradiction in terms to say that the one attacked is privileged only to speak the truth, and not to…
…with the aid of British counsel and without having seen Defendant's British law argument, s6bmits an interpretation of British law directly contradicting Defendant's. 4 • • .~ ·f This precarious support provides an insu…
…primary or substantial purpose, and the judgment of Buckley L.J., even taken on its own, does not go to the extent of contradicting that of Hamilton L.J.: see at p. 856: " I t is not I think necessary . . ."…
…people, more lurid accounts of tawdry sexual encounters, and more exploitive circumstances. Giuffre’s stories have proven wildly contradictory and, even by her own words, have been definitively proven untrue. 4. Giuffre published her false allegations and accusations about Ms…
…Ms. Giuffre provided documents responsive to this request, which included her personal bank records. Defendant takes the contradictory and self-serving position that discovery concerning the personal finances of Ms. Giuffre is appropriate, yet discovery concerning her own finances is…
…in the upcoming weeks. It is currently, however, limited to rebutting the claims of “relevance” made by Plaintiff relating to the at issue waiver. 11 Plaintiff’s argument on this issue is actually internally contradictory. By alleging Fed. R. Evid…