…Sun, Jan 4, 2015 Ghislaine Maxwell: ‘I was not a madam for paedophile’ SOCIALITE Ghislaine Maxwell dismissed claims yesterday that she acted as a “madam” to supply underage girls to US businessman Jeffrey Epstein. PUBLISHED: 00:10, Sun, Jan 4…
…33 IV. Ms. Maxwell’s January 4, 2015, statement is nonactionable. ............................................... 38 V. The defamation claim should be dismissed because the publication is substantially true. ... 39 VI. Plaintiff cannot establish actual malice by clear and convincing evidence. .......................... 40 A.…
…statements, that will do it. … MR. EDWARDS: Sure. … There are two ways in which a case can be dismissed in Florida. One is by way of a court order. The other is by way of a stipulation. That…
…Plaintiff in a false light, and (3) Defendant intentionally inflicted emotional distress upon Plaintiff.1 Presently before the Court is a Motion to Dismiss and Brief in Support filed by Defendant alleging that no justiciable claim or controversy exists. Doc…
…this has been Defendant’s strategy, and the Court should not accept such stonewalling as a litigation tactic. In the Second Circuit, courts have dismissed actions where a party has demonstrated willful disregard for its discovery obligations. Edwards v. Am…
…much to everyone's happiness, including the Court's, 14 and was dismissed shortly thereafter. Two times since May we 15 have asked for agreed upon protocol with the plaintiff's 16 counsel to finish up destroying or exchanging-back…
…33 IV. Ms. Maxwell’s January 4, 2015, statement is nonactionable. ............................................... 38 V. The defamation claim should be dismissed because the publication is substantially true. ... 39 VI. Plaintiff cannot establish actual malice by clear and convincing evidence. .......................... 40 A.…
…2015 WL 4610422 (S.D.N.Y. July 23, 2015) (granting in part motion to compel production). In the Second Circuit, courts have dismissed actions where a party has demonstrated willful disregard for its discovery obligations. Edwards v. Am. Airlines…
…you. All of these documents are clearly 9 eventually subject to discovery in the other case. They're all 10 relevant to the motion to dismiss. We provided you with a -- 11 THE COURT: Thank you very much. 12 MR…
…there 4 is a statement, some kind of a statement from the mediator in 5 the Florida action. When I get a piece of paper that says the 6 Florida action is dismissed, a court order or whatever, then 7 …
… f. the disposition of any case associated with any such Communication, irrespective of whether the matter was sealed, expunged or later dismissed. Response to Interrogatory No. 4 Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33…
…2016. (Doc. #13) On November 30, 2015, contemporaneous with the filing of her Rule 12(b) Motion to Dismiss, Ms. Maxwell also requested of this Court a stay of discovery pursuant to Rule 26(c). (Doc. #17) That motion was…
… f. the disposition of any case associated with any such Communication, irrespective of whether the matter was sealed, expunged or later dismissed. Response to Interrogatory No. 4 Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33…
…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…
…and the charges against Epstein if any. will be dismissed. Page2 of 7 GIUFFRE007598 …
…690 So.2d 725, 729 (Fla. 4the DCA 1997) cause dismissed, (Fla. June 2, 1997) (sanctioning a party for making public discussions that took place during mediation by striking its pleadings and dismissing the case with prejudice: " If the trial…
… f. the disposition of any case associated with any such Communication, irrespective of whether the matter was sealed, expunged or later dismissed. Response to Interrogatory No. 4 Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33…
…objections and interposing appropriate privileges are demanded by the Rules of Civil Procedure. Plaintiff’s hyperbole regarding “stonewalling” and un-reasonable delays in discovery should be dismissed. All of the delays could have been prevented had she served Requests for…
…Communication; f. the disposition of any case associated with any such Communication, irrespective of whether the matter was sealed, expunged or later dismissed. 5. Identify each Communication that You or Your Attorneys have had with any author, reporter, correspondent, columnist…
…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..............................................................................................…
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