…Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S CORRECTED1 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 RULE 26(a) 1 Due to inadvertence…
…Defendant. ________________________________/ 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 RULE 26(a) Case 1:15-cv-07433-LAP…
…Defendant. ________________________________/ 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 RULE 26(a) Case 1:15-cv-07433-LAP…
…Defendant. ________________________________/ 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 RULE 26(a) Case 1:15-cv-07433-LAP…
…cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S CORRECTED1 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 RULE 26(a) …
…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…
…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…
…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…
…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…
…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…
…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…
…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…
…admission or statement given by the accused, or the refusal or failure of the accused to make any statement; (3) The performance of any examinations or tests or the accused’s refusal or failure to submit to an examination or…
…and it nevertheless disclaimed any ability to narrowly tailor any subpoena. Given “its knowledge about the matter under investigation,” the government’s failure to make any effort, much less a “reasonable effort,” to request “only those documents that are relevant…
…Circuit, that it was not yet ripe to be resolved. 8 THE COURT: Thank you. I will share Mr. Cooper's 9 failure to memorize every docket entry in the case. Thank you. 10 Go ahead, ma'am. 11 MS…
…At that time, however, the government did not act. Boies “was particularly frustrated by the failure to pursue a perjury charge [against Maxwell],” reported one person, who recalled him saying, “We have her dead to rights.”5 Id. All of…
…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…
…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…
…Maxwell’s attempt to justify complete closure based on a Non-Party’s failure to object—regardless of the substance of the document that mentions the Non-Party— therefore flies in the face of the presumption of public access. 4…
…adverse inference jury instruction for Defendant’s willful discovery non-compliance, and, at this point, Defendant’s continued willful discovery failures warrant a second adverse inference jury instruction, pursuant to the renewed motion filed by Ms. Giuffre on March 3…