…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)…
…INTRODUCTION ................................................................................................................. 1 FACTUAL BACKGROUND ................................................................................................. 2 I. PLAINTIFF’S FAILURE TO IDENTIFY THE SPECIFIC QUESTIONS CLAIMED UNANSWERE…
…INTRODUCTION ................................................................................................................. 1 FACTUAL BACKGROUND ................................................................................................. 2 I. PLAINTIFF’S FAILURE TO IDENTIFY THE SPECIFIC QUESTIONS CLAIMED UNANSWERE…
…Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ____________________________/ DECLARATION OF MEREDITH SCHULTZ IN SUPPORT OF PLAINTIFF’S BRIEFING REGARDING DEFENANT’S FAILURE TO COMPLY WITH THIS COURT’S ORDER TO PRODUCE HER ELECTRONIC DOCUMENTS AND …
…and Steven A. Williams in support of Plaintiff’s Briefing on an Adverse Inference Instruction Regarding Defendant’s Failure to Comply with This Court’s Orders to Produce Her Electronic Documents and Communications (DE 838) filed on April 7, 2017.…
…Motion for an Adverse Inference Instruction (DE 278). The Motion for Adverse Inference Instruction concerns Defendant’s failures and misconduct regarding electronic discovery, and the Supplement concerns Defendant’s new electronic discovery misconduct that occurred after the motion was filed…
…Thus, her claimed failure to remember all of her doctor’s names does not square with the information readily available to herself and her attorneys. A. Plaintiff Has Failed to Comply with Her Obligations to Respond to Interrogatory Requests as…
… Plaintiff Cannot Base Alleged Lost Income on the Jobs of Others ....................... 6 D. Plaintiff Cannot Refuse to Provide Addresses and Telephone Numbers .............. 6 E. Plaintiff’s Failure to Timely Disclose Required Information has Prejudiced Ms. Maxwell. ...........................................…
…Giuffre requested an adverse inference jury instruction for Defendant’s willful failure to comply with this Court’s Order to produce electronically stored information 2 Case 1:15-cv-07433-LAP Document 659 Filed 03/03/17 Page 3…
…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…
…primary control of a party and is not provided, an adverse inference can be drawn against the withholding party. Such adverse inferences are appropriate as a consequence for failure to make discovery.” Bouzo v. Citibank, N.A., 1993 WL 525114…
…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…
…primary control of a party and is not provided, an adverse inference can be drawn against the withholding party. Such adverse inferences are appropriate as a consequence for failure to make discovery.” Bouzo v. Citibank, N.A., 1993 WL 525114…
…location. To ensure that Defendant is not prejudiced by the failure to provide information about Ms. 5 Case 1:15-cv-07433-LAP Document 1320-37 Filed 01/03/24 Page 7 of 48 Giuffre’s specific residential location, Ms…
…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…
…Court should grant Ms. Giuffre’s request for an adverse inference based on the incurable prejudice she has suffered as a result of Defendant’s failure to comply with her discovery obligations and this Court’s June 20, 2016, Order…
…primary control of a party and is not provided, an adverse inference can be drawn against the withholding party. Such adverse inferences are appropriate as a consequence for failure to make discovery.” Bouzo v. Citibank, N.A., 1993 WL 525114…
…Court should grant Ms. Giuffre’s request for an adverse inference based on the incurable prejudice she has suffered as a result of Defendant’s failure to comply with her discovery obligations and this Court’s June 20, 2016, Order…
…location. To ensure that Defendant is not prejudiced by the failure to provide information about Ms. 5 Case 1:15-cv-07433-LAP Document 1331-3 Filed 01/05/24 Page 7 of 48 Giuffre’s specific residential location, Ms…
…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…