gov.uscourts.nysd.447706.895.0.pdf PDF
…GIUFFRE, Plaintiff, v. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. --------------------------------------------------X Declaration Of Laura A. Menninger In Support Of Defendant’s Response in…
…GIUFFRE, Plaintiff, v. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. --------------------------------------------------X Declaration Of Laura A. Menninger In Support Of Defendant’s Response in…
…old. Id., ¶ 51. Evidence also shows that when two of the victims, one age 15, attempted to 2 Case 1:15-cv-07433-LAP Document 1111 Filed 09/01/20 Page 3 of 14 escape from Little St. James…
…to even include Ms. Giuffre’s name as a search term (either in reality or in the position she took on Friday) is evidence of Defendant’s continued bad faith and complete avoidance of her discovery obligations. The case centers…
…from 1999-2002. In light of this clear and persistent pattern of recalcitrance, the Court should instruct the jury that it can draw an adverse inference that the Defendant has concealed relevant evidence. Even if Defendant were, at this late…
…to even include Ms. Giuffre’s name as a search term (either in reality or in the position she took on Friday) is evidence of Defendant’s continued bad faith and complete avoidance of her discovery obligations. The case centers…
…books, coupled with the reasonable belief that the officer was the custodian of such records, was prima facie evidence of the officer's contempt of subpoenas duces tecum.”). And Kellen’s reasons (if any) for failing to respond are irrelevant…
…future pain and suffering, mental anguish, humiliation, embarrassment, loss of self-esteem.” Plaintiff’s claims for these categories of damages must be stricken or evidence as to these damages precluded from trial under Fed. R. Civ. P. 37(b)(2…
…to even include Ms. Giuffre’s name as a search term (either in reality or in the position she took on Friday) is evidence of Defendant’s continued bad faith and complete avoidance of her discovery obligations. The case centers…
…(broker Shari Scharfer Rollins, of Douglas Elliman, did not return calls). The transfers of assets, likely out of the jurisdiction of this Court, provides evidence of consciousness of criminal guilt and civil liability. Clearly, Ms. Giuffre is entitled to explore…
…future pain and suffering, mental anguish, humiliation, embarrassment, loss of self-esteem.” Plaintiff’s claims for these categories of damages must be stricken or evidence as to these damages precluded from trial under Fed. R. Civ. P. 37(b)(2…
…future pain and suffering, mental anguish, humiliation, embarrassment, loss of self-esteem.” Plaintiff’s claims for these categories of damages must be stricken or evidence as to these damages precluded from trial under Fed. R. Civ. P. 37(b)(2…
…all of the Dershowitz testimony is inadmissible under the Rules of Evidence in any event. FACTUAL BACKGROUND 1 Case 1:15-cv-07433-LAP Document 561 Filed 01/27/17 Page 6 of 22 Defendant designated for use in…
…future pain and suffering, mental anguish, humiliation, embarrassment, loss of self-esteem.” Plaintiff’s claims for these categories of damages must be stricken or evidence as to these damages precluded from trial under Fed. R. Civ. P. 37(b)(2…
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