gov.uscourts.nysd.447706.46.0.pdf PDF
…Avenue Denver, CO 80203 303.831.7364 TABLE OF CONTENTS INTRODUCTION ..............................................…
Found 75 results
for “failure”
in 171ms
gov.uscourts.nysd.447706.962.0.pdf PDF
…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. …
gov.uscourts.nysd.447706.279.0.pdf PDF
…Plaintiff, Virginia Giuffre, hereby submits this Motion for an Adverse Inference Instruction to the jury for failure to comply with a Court Order pursuant to Rule 37(b); for failure to preserve electronically stored information pursuant to Rule 37(e)…
gov.uscourts.nysd.447706.1188.0.pdf PDF
…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…
gov.uscourts.nysd.447706.1015.0.pdf PDF
…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…
gov.uscourts.nysd.447706.1332.14.pdf PDF
…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. …
gov.uscourts.nysd.447706.1330.16.pdf PDF
…Court and Ms. Maxwell’s time and needlessly multiply these proceedings. Courts in this district routinely deny motions based on failure to confer prior to the motion when such conferral is required by the Rules or Court Order. Prescient Partners…
gov.uscourts.nysd.447706.1320.17.pdf PDF
…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.447706.31.0_1_1.pdf PDF
…that the failure to identify the 7 individuals to whom the statement allegedly was made and the 8 content of that statement is fatally defective to an attempt to 9 state a libel or slander cause of action. 10 In…
gov.uscourts.nysd.447706.1256.12.pdf PDF
…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…
gov.uscourts.nysd.447706.1325.18.pdf PDF
…that the failure to identify the 7 individuals to whom the statement allegedly was made and the 8 content of that statement is fatally defective to an attempt to 9 state a libel or slander cause of action. 10 In…
1320-17.pdf PDF
…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.447706.42.0.pdf PDF
…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…
gov.uscourts.nysd.447706.29.1.pdf PDF
…a Complaint must be dismissed for “failure to state a claim upon which relief can be granted.” Detailed factual pleading is not required – Rule 8(a)(2) calls for a 1 This case was removed to this Court by Defendant…
gov.uscourts.nysd.447706.185.8.pdf PDF
…categorically, as Plaintiffs have done. Dershowitz also filed with the Court a Motion for Finding of Waiver Based on Plaintiffs’ Failure to Provide a Privilege Log or, in the alternative, to Compel Plaintiffs to Provide an Itemized Privilege Log, which…
gov.uscourts.nysd.447706.967.0.pdf PDF
…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 …
gov.uscourts.nysd.447706.1332.11.pdf PDF
… THE MOTION TO COMPEL SHOULD BE DENIED BECAUSE OF PLAINTIFF’S FAILURE TO COMPLY WITH THE RULES. As discussed in our response (Doc.653) the failure to comply with the rules is an independent ground for denial of a motion…
gov.uscourts.nysd.447706.1328.20.pdf PDF
…1990s and early 2000s, Plaintiff’s substantial substance abuse, her lack of credibility, her failures of memory and her selective use of law enforcement. Regarding the year 2015, the police reports demonstrate Plaintiff’s tumultuous home life, bearing no relationship…
gov.uscourts.nysd.447706.1199.6_1.pdf PDF
…1990s and early 2000s, Plaintiff’s substantial substance abuse, her lack of credibility, her failures of memory and her selective use of law enforcement. Regarding the year 2015, the police reports demonstrate Plaintiff’s tumultuous home life, bearing no relationship…
gov.uscourts.nysd.447706.35.0.pdf PDF
…567 F.Supp 777 (S.D.N.Y. 1983) (failure to produce documents and supply adequate answers to interrogatories without justifiable excuse warranted the dismissal of the complaint). The blatant nature of the defendant’s failure to participate in discovery…