…III. EACH OF MS. MAXWELL’S OBJECTIONS IS APPROPRIATE ..................................... 6 IV. PLAINTIFF’S FAILURE TO CONFER WITH MS. MAXWELL PRIOR TO FILING HER MOTIONS TO COMPEL IS DISPOSITIVE ............................................................. 13 …
…2016). Maxwell’s failure to notify the public of her submission under seal is made more egregious by the fact that Maxwell did not even notify Intervenors – a party to this litigation – that the letter was sent to the Court…
… Case 1:15-cv-07433-LAP Document 749 Filed 03/17/17 Page 3 of 9 13. Plaintiff’s failure to pay her personal tax obligations is relevant to her character for truthfulness (Motion in Limine 13) ............................................................................... 22 14…
…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…
…Support Of Defendant's Reply In Support Of Motion for Rule 37(b) &(c) Sanctions For Failure To Comply With Court Order And Failure To Comply With Rule 26(a) under seal pursuant to this Court's Protective Order (Doc…
…to Ms. Giuffre and her minor children, she is not at liberty to reveal her present residential location. To ensure that Defendant is not prejudiced by the failure to provide information about Ms. Giuffre’s specific residential location, Ms. Giuffre…
…location. To ensure that Defendant is not prejudiced by the failure to provide information about Ms. 5 Case 1:15-cv-07433-LAP Document 1320-37 Filed 01/03/24 Page 7 of 48 Giuffre’s specific residential location, Ms…
…location. To ensure that Defendant is not prejudiced by the failure to provide information about Ms. 5 Case 1:15-cv-07433-LAP Document 1331-3 Filed 01/05/24 Page 7 of 48 Giuffre’s specific residential location, Ms…
…to Ms. Giuffre and her minor children, she is not at liberty to reveal her present residential location. To ensure that Defendant is not prejudiced by the failure to provide information about Ms. Giuffre’s specific residential location, Ms. Giuffre…
…to Ms. Giuffre and her minor children, she is not at liberty to reveal her present residential location. To ensure that Defendant is not prejudiced by the failure to provide information about Ms. Giuffre’s specific residential location, Ms. Giuffre…
…actions, the Defendants intended to cause, and did caluie, Plaintiff to believe that failure to perform the actions they requested would result in physical restraint and potential harm to her person, as well as harm to her reputation, ernployability, and…
…location. To ensure that Defendant is not prejudiced by the failure to provide information about Ms. 5 Case 1:15-cv-07433-LAP Document 1320-37 Filed 01/03/24 Page 7 of 48 Giuffre’s specific residential location, Ms…
…to Ms. Giuffre and her minor children, she is not at liberty to reveal her present residential location. To ensure that Defendant is not prejudiced by the failure to provide information about Ms. Giuffre’s specific residential location, Ms. Giuffre…
…location. To ensure that Defendant is not prejudiced by the failure to provide information about Ms. 5 Case 1:15-cv-07433-LAP Document 235-3 Filed 06/21/16 Page 7 of 48 Giuffre’s specific residential location, Ms…
…this case, the cost and expense of such a deposition in the u.s. Virgin Islands and your failure to pursue in good faith a deposition of Mr. Epstein during the 5 ~ months of discovery available in this case…