…data, and requests that this Court enter an adverse inference jury instruction for this willful violation of this Court’s orders. I. BACKGROUND The earliest-dated email Defendant has produced in this litigation is from July 18, 2009. (GM_00069)…
…a), stating as follows: CERTIFICATE OF CONFERRAL The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an attempt to obtain records and interrogatory responses Ordered by the Court, including by letter dated April 25, 2016, outlining the…
…a), stating as follows: CERTIFICATE OF CONFERRAL The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an attempt to obtain records and interrogatory responses Ordered by the Court, including by letter dated April 25, 2016, outlining the…
…a), stating as follows: CERTIFICATE OF CONFERRAL The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an attempt to obtain records and interrogatory responses Ordered by the Court, including by letter dated April 25, 2016, outlining the…
…a), stating as follows: CERTIFICATE OF CONFERRAL The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an attempt to obtain records and interrogatory responses Ordered by the Court, including by letter dated April 25, 2016, outlining the…
…the parties to submit search terms to the Court on August 1, 2016, advising that “[a] briefing schedule and the submission date will be set after search terms are determined.” (DE 301). Pursuant to this Court’s July 22, 2016…
…the parties to submit search terms to the Court on August 1, 2016, advising that “[a] briefing schedule and the submission date will be set after search terms are determined.” (DE 301). Pursuant to this Court’s July 22, 2016…
…the parties to submit search terms to the Court on August 1, 2016, advising that “[a] briefing schedule and the submission date will be set after search terms are determined.” (DE 301). Pursuant to this Court’s July 22, 2016…
…352). To date, Defendant has made no document production pursuant to those Orders. 2 Case 1:15-cv-07433-LAP Document 375 Filed 08/17/16 Page 3 of 4 With the pending motion for an adverse inference instruction…
…men with ample resources are employing lawyers and occupying space and time in the justice system to continue their personal feud. Regrettably there is to date no apparent basis to avoid the unappetizing task of ruling on these motions.”). Moreover…
…attached to this brief as Exhibit A. 2 The Brown minimal redactions encompass: (1) “personally identifying information such as personal phone numbers, contact lists, birth dates, and social security numbers;” (2) “the names of alleged minor victims of sexual abuse…
Comments