…OF SIGRID S. MCCAWLEY IN PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION FOR DEFENDANT’S RULE 37(b) &(c) SANCTIONS FOR FAILURE TO COMPLY WITH COURT ORDER AND FAILURE TO COMPLY WITH RUILE 26(a) I, Sigrid S…
…OF SIGRID S. MCCAWLEY IN PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION FOR DEFENDANT’S RULE 37(b) &(c) SANCTIONS FOR FAILURE TO COMPLY WITH COURT ORDER AND FAILURE TO COMPLY WITH RUILE 26(a) I, Sigrid S…
…Entry1 Plaintiff’s Position 231: Defendant’s Motion for Rule 37(b) & (c) for Failure to Unseal and redact only (1) medical information and (2) names and Comply with Court Order identifying information of Non-Parties who have objected to…
…this Reply in support of her motion for an Order to Show Cause requiring plaintiff Virginia Giuffre and her lawyers to state why this Court should not impose sanctions for their failure to comply with the Court’s Protective Order. …
…Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ____________________________/ DECLARATION OF MEREDITH SCHULTZ IN SUPPORT OF PLAINTIFF’S BRIEFING REGARDING DEFENANT’S FAILURE TO COMPLY WITH THIS COURT’S ORDER TO PRODUCE HER ELECTRONIC DOCUMENTS AND …
…2 Ms. Maxwell notes that Response Brief is filled with irrelevant information and misleading deposition excerpts that are wholly irrelevant to the underlying motion for sanctions for failure to comply with discovery obligations relating to plaintiff’s medical information. These…
…LAP Document 1226 Filed 08/04/21 Page 2 of 4 August 4, 2021 Page 2 of 4 The second issue arises from the parties’ failure to properly make redactions …
…Thus, her claimed failure to remember all of her doctor’s names does not square with the information readily available to herself and her attorneys. A. Plaintiff Has Failed to Comply with Her Obligations to Respond to Interrogatory Requests as…
…moved for an Order to Show Cause requiring plaintiff Virginia Giuffre ("Giuffre" or the " Pl a i ntiff " ) to state why this Court should not impose sanctions for their failure to comp l y with this Court ' s Protective Order …
…2 Ms. Maxwell notes that Response Brief is filled with irrelevant information and misleading deposition excerpts that are wholly irrelevant to the underlying motion for sanctions for failure to comply with discovery obligations relating to plaintiff’s medical information. These…
…230 Virginia Giuffre filed by Ghislaine Maxwell. Redacted Motion to Compel- Judicial MOTION for Sanctions 37(b) & (c) for Failure to Document 06/20/2016 2…
…to challenge the propriety of any designation of discovery material under this Order at the time the designation is made, and a failure to do so shall not preclude a subsequent challenge thereto. Moreover, failure to challenge the designation of …
…d, and underst ands that the failure to recommendation regardi do so will be a breach of the agreement. sation In consideration ofEpstciD's agrcemont to plead guilty and to provide compen …
…As to the former, the Protocol explicitly advised Non-Parties that their participation is “optional” and that failure to participate “shall not be deemed consent to the unsealing of any Sealed Materials.” DE 1108 at 3(f). The Court also…
…2 Ms. Maxwell notes that Response Brief is filled with irrelevant information and misleading deposition excerpts that are wholly irrelevant to the underlying motion for sanctions for failure to comply with discovery obligations relating to plaintiff’s medical information. These…
…No bullets or numbering, Tab stops: 1", Formatted: Font: 12 pt failure to do so shall not preclude a subsequent challenge thereto. Moreover, …
…pages at issue, that decision—which appears to have been made without particularized review—amounts to an abuse of discretion.37 In light of the District Court’s failure to conduct an individualized review of the sealed materials, it is…
…No bullets or numbering, Tab stops: 1", Formatted: Font: 12 pt failure to do so shall not preclude a subsequent challenge thereto. Moreover, …
…2 Ms. Maxwell notes that Response Brief is filled with irrelevant information and misleading deposition excerpts that are wholly irrelevant to the underlying motion for sanctions for failure to comply with discovery obligations relating to plaintiff’s medical information. These…
…637 Filed 02/22/17 Page 12 of 12 CERTIFICATE OF CONFERRAL Undersigned counsel certifies that she raised the failure to produce issue in opposition to Defendant’s Summary Judgment and also raise it at oral argument with the Court…