…the commencement of this litigation (as shown by the document at issue) is - evidence to the contrary. Ms. Giuffre should be able to cross her with that email and ask related questions. Therefore, both of these documents are highly relevant…
…2900217, at *1 (S.D.N.Y. Oct. 4, 2007) (Sweet, J.) (denying motion and cross motion based on failure to confer, noting “[m]ere correspondence, absent exigent circumstances not present here, does not satisfy the requirement”); Myers v. Andzel…
…05/24 Page 5 of 10 content of that email, a communication with a key witness, nor did she have the opportunity to use it to cross some of Defendant’s evasive answers. Additionally, due to the late production, Ms…
…he is not, then there is no rebuttal witness, and none to cross examine. II. WAS NOT PROPERLY “REFRESHED” AND THE READING OF THE HEARSAY POLICE REPORT IS INADMISSABLE The use of the deposition testimony of , and the reading or…
…a belief as the allegations in paragraph 5. 1 Because Plaintiff’s Complaint repeats paragraph numbers throughout, this Answer tracks the headings and paragraph numbers contained therein to facilitate cross-reference between the two documents. 3 …