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gov.uscourts.nysd.447706.371.2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.371.2 18 pg
P21 V15 V9 D1 D4

…repeat a general objection for emphasis or for some other reason. The failure to include any general objection in any specific response does not waive any general objection to that request. 10. The Requests seek information that is confidential and…

gov.uscourts.nysd.447706.468.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.468.0 12 pg
V9 P24 V15 V13 D1

…primary control of a party and is not provided, an adverse inference can be drawn against the withholding party. Such adverse inferences are appropriate as a consequence for failure to make discovery.” Bouzo v. Citibank, N.A., 1993 WL 525114…

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