…second deposition was complete. While Ms. Giuffre attempted to confer with Defendant to secure her agreement to be deposed on this new information, Defendant refused to sit for a follow up deposition (despite the fact that Ms. Giuffre agreed to…
…mutually agreed” upon search terms. It is impossible for Ms. Giuffre’s counsel to begin working with opposing counsel to craft appropriate search terms when they refuse to extend minimal cooperation - first by completely ignoring Ms. Giuffre’s multiple attempts…
…mutually agreed” upon search terms. It is impossible for Ms. Giuffre’s counsel to begin working with opposing counsel to craft appropriate search terms when they refuse to extend minimal cooperation - first by completely ignoring Ms. Giuffre’s multiple attempts…
…mutually agreed” upon search terms. It is impossible for Ms. Giuffre’s counsel to begin working with opposing counsel to craft appropriate search terms when they refuse to extend minimal cooperation - first by completely ignoring Ms. Giuffre’s multiple attempts…
…Proceedings” (DE 101), seeks to compel Ms. Giuffre to disclose the name of law enforcement agency with which she is cooperating in an investigation into Jeffrey Epstein’s sex trafficking. Defendant has not conferred with Ms. Giuffre on her request…
…4) unless the applicant's interest is adequately represented by existing parties. Rhinebeck Cent. Sch. Dist., 224 F.R.D. at 155 (citing Wash. Elec. Cooperative, Inc. v. Mass. Municipal Wholesale Elec. Co., 922 F.2d 92, 96 (2d Cir…
…HSE investigation and that B experience from earlier investigations suggested that the HSE would probably not be interested in Total’s investigation and their main interest in Total at that stage was to be confident that they were cooperati…