gov.uscourts.nysd.447706.46.0.pdf PDF
…Avenue Denver, CO 80203 303.831.7364 TABLE OF CONTENTS INTRODUCTION ..............................................…
Found 26 results
for “failure”
in 285ms
gov.uscourts.nysd.447706.45.0.pdf PDF
…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 …
gov.uscourts.nysd.447706.1331.12.pdf PDF
…Simply put, she should not be allowed to benefit from her obvious failure to properly disclose Ms. Ransome. Ms. Ransome's Testimonv is ot Cumulative And Has Highly Relevant Evidence Defendant also advances the remarkable argument that it is "unlikely…
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…
gov.uscourts.nysd.447706.1218.49.pdf PDF
…LLP—have a valid factual basis for continuing to press Ms. Giuffre’s false allegations. Mr. Cassell’s effort is an unmitigated failure, as this declaration demonstrates. 6. While much of the Cassell Declaration goes far beyond what is reasonably…
gov.uscourts.nysd.447706.1307.4.pdf PDF
…Beach mansion, he was followed by strange men and “investigated”. He also has made public statements that he sent to victims regarding the failure of the government to properly handle the matter. Reiter is relevant to many issues, among others…
gov.uscourts.nysd.447706.1296.12.pdf PDF
…For example, Defendant attempts to suggest that Ms. Giuffre’s counsel was not diligent in disclosing Ms. Ransome. Yet if there was any failure of disclosure here, it was entirely Defendant’s failure. Clearly, witness Ms. Ransome is someone who…
gov.uscourts.nysd.447706.1320.10.pdf PDF
…at one point scolding Ms. Sjoberg for failing to “finish [her] job” after Ms. Sjoberg massaged Epstein without completing the sex act, and because of this failure, Defendant, instead, had to “finish [her] job for her” and cause Epstein and…
gov.uscourts.nysd.447706.1296.9.pdf PDF
…For example, Defendant attempts to suggest that Ms. Giuffre’s counsel was not diligent in disclosing Ms. Ransome. Yet if there was any failure of disclosure here, it was entirely Defendant’s failure. Clearly, witness Ms. Ransome is someone who…
gov.uscourts.nysd.447706.1296.13.pdf PDF
…did not expressly make any such claim nor did they describe the nature of the withheld documents. The witness’s unjustified failure to provide a privilege log as to Responses 1-3 and 5 effected a waiver of any privilege…
gov.uscourts.nysd.447706.1332.7.pdf PDF
…For example, Defendant attempts to suggest that Ms. Giuffre’s counsel was not diligent in disclosing Ms. Ransome. Yet if there was any failure of disclosure here, it was entirely Defendant’s failure. Clearly, witness Ms. Ransome is someone who…
gov.uscourts.nysd.447706.1330.4.pdf PDF
…LLP—have a valid factual basis for continuing to press Ms. Giuffre’s false allegations. Mr. Cassell’s effort is an unmitigated failure, as this declaration demonstrates. 6. While much of the Cassell Declaration goes far beyond what is reasonably…
gov.uscourts.nysd.447706.1332.9.pdf PDF
…did not expressly make any such claim nor did they describe the nature of the withheld documents. The witness’s unjustified failure to provide a privilege log as to Responses 1-3 and 5 effected a waiver of any privilege…
gov.uscourts.nysd.447706.1295.11.pdf PDF
…protected, will enable the parties to assess the claim. An “unjustified failure to list privileged documents on the required log of withheld documents in a timely and proper manner operates as a waiver of any applicable privilege,” OneBeacon Ins. Co…
gov.uscourts.nysd.447706.1137.12_2.pdf PDF
…Beach mansion, he was followed by strange men and “investigated”. He also has made public statements that he sent to victims regarding the failure of the government to properly handle the matter. Reiter is relevant to many issues, among others…
gov.uscourts.nysd.447706.1256.3.pdf PDF
…Beach mansion, he was followed by strange men and “investigated”. He also has made public statements that he sent to victims regarding the failure of the government to properly handle the matter. Reiter is relevant to many issues, among others…
gov.uscourts.nysd.447706.179.0.pdf PDF
…Indeed, she cannot. 3 Moreover, failure to list these professionals in Ms. Giuffre’s log would risk waiver of their privilege. In addition to codifying the work-product doctrine, the Federal Rules of Civil Procedure also establish that, “the [ ] facts…
gov.uscourts.nysd.447706.1330.15.pdf PDF
…43 THE WITNESS: Fifth. Id. at 226-29 . 12. Epstein was also asked specific questions with regard to his failure to produce certain records, such as telephone records regarding his communications with Maxwell. Epstein also took the Fifth rather than…
gov.uscourts.nysd.447706.1334.1.pdf PDF
…For example, Defendant attempts to suggest that Ms. Giuffre’s counsel was not diligent in disclosing Ms. Ransome. Yet if there was any failure of disclosure here, it was entirely Defendant’s failure. Clearly, witness Ms. Ransome is someone who…
gov.uscourts.nysd.447706.43.0.pdf PDF
…improper, blanket objections. This Defendant appears to simply not want to participate in the discovery process, and her failure to respond substantively is another effort to delay and prejudice Ms. Giuffre’s ability to prosecute her case. II. ARGUMENT 1…