…INTRODUCTION ................................................................................................................. 1 FACTUAL BACKGROUND ................................................................................................. 2 I. PLAINTIFF’S FAILURE TO IDENTIFY THE SPECIFIC QUESTIONS CLAIMED UNANSWERE…
…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…
…INTRODUCTION ................................................................................................................. 1 FACTUAL BACKGROUND ................................................................................................. 2 I. PLAINTIFF’S FAILURE TO IDENTIFY THE SPECIFIC QUESTIONS CLAIMED UNANSWERE…
…Avenue Denver, CO 80203 303.831.7364 TABLE OF CONTENTS INTRODUCTION ..............................................…
…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…
…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 …
…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…
…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…
…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…
…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…
…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…
…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…
…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…
… 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…
…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 …
… 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…
…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…
…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…
…Maxwell. Id. Without downplaying Doe 107’s concerns, Doe 107’s failure to provide any specific support for this assertion is fatal to their objection. Notably, Doe 107’s objection does not provide any indication of where they are living…
…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…