…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)…
…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…
…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…
…I ask that they stop," said Ghislaine Maxwell A number of newspapers have shown a complete lack of accuracy in their reporting of this story and a failure to carry out the most elementary investigation or any real due diligence…
…Maxwell. and customised feeds just for media. "A number of newspapers have shown a complete lack of …
…the Information Sought by the Subpoena ........................................... 15 II. THE SUBPOENA SHOULD ALSO BE QUASHED UNDER RULE 45 FOR FAILURE TO ALLOW A REASONABLE TIME FOR COMPLIANCE AND IMPOSING AN UNDUE BURDEN ..........…
…Plaintiff Has Not Properly Pled Special Damages .................................................. 23 a. The Alleged Defamatory Statement is Not Defamatory Per Se .......................... 23 b. Failure to Allege Special Damages Warrants Dismissal ..................................... 24 CONCLUSION ................…
…damages are typically not amenable to the type of disclosures contemplated by Rule 26(a)(1)(A)(iii), and have held that the failure to disclose a number or calculation for such damages was substantially justified.” See Murray v. Miron…
…162 (2d Cir. 2012). “Spoliation is ‘the destruction of evidence, or the failure to preserve property for another's use as evidence in pending or reasonably foreseeable litigation.’” MASTR Adjustable Rate Mortgages Trust, 295 F.R.D. at 82 (quoting…
…motion, in part, as untimely). “Spoliation is the destruction or significant alteration of evidence, or the failure to preserve property for another's use as evidence in pending or reasonably foreseeable litigation.” Kraus v. General Motors Corp., 2007 WL 3146911…
…the summary-judgment argument should be Case 1:15-cv-07433-LAP Document 829 Filed 04/03/17 Page 3 of 4 Judge Sweet April 3, 2017 Page 3 designated “confidential.” That is a failure at liftoff. See Vazquez v…
…to take reasonable, necessary, appropriate and feasible steps to mitigate her alleged damages, and to the extent of such failure to mitigate, she should be barred from recovering some or all of the alleged damages she seeks. 9 38. …
…2d Cir. 2012). " Spoliation is 'the destruction of evidence, or the failure to preserve property for I another's use as evidence in pending or reasonably foreseeable litigation."' MASTR Adjustable I Rate Mortgages Trust, 295 F.R.D. at 82…
…Indeed, Plaintiff’s second deposition still cannot be 8 Case 1:15-cv-07433-LAP Document 1330-17 Filed 01/05/24 Page 10 of 12 - scheduled because Plaintiff persists in her failures …