…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…
…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…
…Entry1 Plaintiff’s Position 231: Defendant’s Motion for Rule 37(b) & (c) for Failure to Unseal and redact only (1) medical information and (2) names and Comply with Court Order identifying information of Non-Parties who have objected to…
…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…
…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 …
…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…
…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…
…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…
…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…
…arising out of the World Trade Center (WTC) bombing, in which the plaintiffs alleged injuries resulting from the negligent failure of the defendant Port Authority of New York and New Jersey to implement security measures, the defendant was not required…
…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…
…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…
…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 ................…