…memoranda, witness interviews, and other material’” created in preparation for litigation and trial (emphasis added) (internal citation omitted)). Indeed, “protection of witness interviews has been one of the focuses of the attorney 21 relevance of the questions were tenuous at…
…relevant documents. (DE 345 at pg. 8). However, it appears that Jeffrey Epstein created the mindspring.org accounts to communicate with his household and with his employees, and did, in fact, communicate with them this way. As previously recounted, Jeffrey…
…memoranda, witness interviews, and other material’” created in preparation for litigation and trial (emphasis added) (internal citation omitted)). Indeed, “protection of witness interviews has been one of the focuses of the attorney 21 relevance of the questions were tenuous at…
…or documents concerning any police reports, that were created concerning such claims of sexual assault; and (3) documents concerning any communications received by You (or Your agents or attorneys) by other individuals that reference any sexual assault of Plaintiff while…
…shall be produced in its native form; that is, in the form in which the information was customarily created, used and stored by the native application employed by the producing party in the ordinary course of business. 8. Defendant does…
…considered to be within the relevant time frame if it refers or relates to communications, meetings or other events or documents that occurred or were created within that time frame, regardless of the date of creation of the responsive Document. …
…or documents concerning any police reports, that were created concerning such claims of sexual assault; and (3) documents concerning any communications received by You (or Your agents or attorneys) by other individuals that reference any sexual assault of Plaintiff while…
…expert testimony if the proponent of the testimony tries to secure the expert’s voluntary attendance and demonstrates that no similar expert is available. These judicially-created requirements have been applied in addition to the requirements of Fed. R. Evid…
…the cause of the incident so that lawyers could be properly instructed for the purposes of the anticipated civil and criminal proceedings. It is in this context that Total’s Accident Investigation Team (“AIT”) was created on Monday 12 December…
…27, 2006) (briefs and supporting papers submitted in connection with a dispute over the confidentiality of discovery materials were “created by or at the behest of counsel and presented to a court in order to sway a judicial decision” and…
…because a “party’s failure to produce evidence within its control creates a presumption that evidence would be unfavorable to that party” an adverse inference should be applied with respect to Defendant’s failure to produce data from the email…
…because a “party’s failure to produce evidence within its control creates a presumption that evidence would be unfavorable to that party” an adverse inference should be applied with respect to Defendant’s failure to produce data from the email…