…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 this Court’s Protective Order (Doc.62) and Opinion issued on November 14…
…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…
…Giuffre' 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 to Rule 26(a) and certain accompanying exhibits under seal pursuant 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. …
…RWS GHISLAINE MAXWELL, Defendant. --------------------------------------------------X Declaration Of Laura A. Menninger In Support Of Defendant’s Motion For Rule 37(B) &(C) Sanctions For Failure To Comply With Court Order And Failure To Comply With …
…RWS GHISLAINE MAXWELL, Defendant. --------------------------------------------------X Declaration Of Laura A. Menninger In Support Of Defendant’s Motion For Rule 37(B) &(C) Sanctions For Failure To Comply With Court Order And Failure To Comply With …
…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 …
…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 this Court’s Protective Order (Doc.62) and Opinion issued on November 14…
…Plaintiff's Motion for Extension of Time to Complete Depositions 231: Defendant's Motion for Rule 37(b) & (c) for Failure to Comply with Court Order and Sanctions for Failure to Comply with Rule 26(a) 279: Plaintiff…
…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…
…deposition will not exceed a total of four hours. The two separate issues relate to (1) Defendant’s failure to answer certain questions at her deposition and (2) her late production of important emails. These two issues developed as follows. …
…3 Honorable Loretta A. Preska November 18, 2020 Page 2 Whereas Plaintiff suggests that the failure to file an objection results in an automatic unsealing of a Non-Party’s name, the Protocol provides otherwise, requiring the Court to undertake…
…The failure to include any general objection in any specific response does not waive any general objection to that request. 1 Case 1:15-cv-07433-LAP Document 1325-19 Filed 01/04/24 Page 4 of 20 10…
…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…
…In fact, for the most part, her failures to actively pursue depositions with these witnesses qualifies as in-excusable neglect: She frittered away seven of the eight months of the discovery period and now has placed Ms. Maxwell, this Court…
…in the past or currently uses.” (Emphasis added). There can be no excuse for failure to do so and no excuse for continuing to refuse to disclose all of her email accounts. B. Substantial Data is Missing from the Defendant. …
…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 …
…HBP, 2012 WL 4791804, at *6 (S.D.N.Y. Oct. 9, 2012) (failure to make any attempts to resolve any specific discovery disputes “alone is a sufficient ground for denying the motion [to compel]”); Prescient Partners, L.P. v…