…in this case. That testimony has no bearing on the issue of whether Plaintiff violated a Court Order to produce medical records (indeed none of the witnesses discussed know a single thing about Plaintiff’s medical conditions), and Plaintiff’s…
…17 II. STRIKING CLAIMS FOR MEDICAL AND EMOTIONAL DISTRESS DAMAGES IS CONSISTENT WITH THE PURPOSE OF RULE 37, COMMENSURATE WITH THE INFORMATION WITHHELD, AND LESS HARSH THAN THE AVAILABLE DISMISSAL SANCTION..............................................................................................…
…17 II. STRIKING CLAIMS FOR MEDICAL AND EMOTIONAL DISTRESS DAMAGES IS CONSISTENT WITH THE PURPOSE OF RULE 37, COMMENSURATE WITH THE INFORMATION WITHHELD, AND LESS HARSH THAN THE AVAILABLE DISMISSAL SANCTION..............................................................................................…
…17 II. STRIKING CLAIMS FOR MEDICAL AND EMOTIONAL DISTRESS DAMAGES IS CONSISTENT WITH THE PURPOSE OF RULE 37, COMMENSURATE WITH THE INFORMATION WITHHELD, AND LESS HARSH THAN THE AVAILABLE DISMISSAL SANCTION..............................................................................................…
…in this case. That testimony has no bearing on the issue of whether Plaintiff violated a Court Order to produce medical records (indeed none of the witnesses discussed know a single thing about Plaintiff’s medical conditions), and Plaintiff’s…
…17 II. STRIKING CLAIMS FOR MEDICAL AND EMOTIONAL DISTRESS DAMAGES IS CONSISTENT WITH THE PURPOSE OF RULE 37, COMMENSURATE WITH THE INFORMATION WITHHELD, AND LESS HARSH THAN THE AVAILABLE DISMISSAL SANCTION..............................................................................................…
…L. GIUFFRE, PLAINTIFF, V. 15-cv-07433-RWS GHISLAINE MAXWELL, DEFENDANT. --------------------------------------------------X MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR A STAY OF DISCOVERY PENDING DECISION ON DEF…
…172, Maxwell contends that all redactions should remain in place because the document contains “references” to her deposition testimony and a Non-Party’s deposition testimony, and she cites the same countervailing interests discussed in Part IV, supra. Maxwell Mem…
…to manipulate the process prescribed by the Protocol to file multiple objections or otherwise to create undue delay. This is not such a circumstance. As discussed above, it is far more likely that Does 1 and 2 misunderstood the somewhat …
…of the dispute among the original parties to the litigation because this litigation is closed (other than with respect to pending disputes over unsealing and third-party access to documents) and because the USVI’s substantial interests, discussed inter alia…
…108 (2d Cir. 2002)). Furthermore, as discussed in detail in Ms. Giuffre’s Motion for an Adverse Inference Instruction (DE 315) and Supplement Motion for Adverse Inference Instruction (DE 338), an adverse inference is appropriate regarding the documents that Defendant…
…108 (2d Cir. 2002)). Furthermore, as discussed in detail in Ms. Giuffre’s Motion for an Adverse Inference Instruction (DE 315) and Supplement Motion for Adverse Inference Instruction (DE 338), an adverse inference is appropriate regarding the documents that Defendant…
…preserve it or by failing to produce information because relevant data has been destroyed—Rule 37(b) of the Federal Rules of Civil Procedure provides that the court may impose a range of sanctions, including dismissal or judgment by default…
…Capital Cities Communications, 82 N.Y.2d 466, 479 (1993). As discussed below, because the limited scope of any financial information permitted related to punitive damages, a net worth statement produced after determination of summary judgment does not prejudice Plaintiff…
…108 (2d Cir. 2002)). Furthermore, as discussed in detail in Ms. Giuffre’s Motion for an Adverse Inference Instruction (DE 315), an adverse inference is appropriate regarding the documents that Defendant is withholding under the Second Circuit’s test set…
…108 (2d Cir. 2002)). Furthermore, as discussed in detail in Ms. Giuffre’s Motion for an Adverse Inference Instruction (DE 315) and Supplement Motion for Adverse Inference Instruction (DE 338), an adverse inference is appropriate regarding the documents that Defendant…
…108 (2d Cir. 2002)). Furthermore, as discussed in detail in Ms. Giuffre’s Motion for an Adverse Inference Instruction (DE 315), an adverse inference is appropriate regarding the documents that Defendant is withholding under the Second Circuit’s test set…
…to protect not only its own interest in covering this case, but also to protect the interests of the public at large. 2.0 Analysis As discussed herein, there is no proper basis to deny Movant access to the information…
…Ms. Giuffre respectfully requests that this Court Reopen Defendant’s deposition to (1) answer lines of questions discussed in Ms. Giuffre’s Motion to Enforce the Court’s Order and Direct Defendant to Answer Deposition Questions Filed under Seal (DE…
…108 (2d Cir. 2002)). Furthermore, as discussed in detail in Ms. Giuffre’s Motion for an Adverse Inference Instruction (DE 315), an adverse inference is appropriate regarding the documents that Defendant is withholding under the Second Circuit’s test set…