…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…
…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…
…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…
…the Information Sought by the Subpoena ........................................... 15 II. THE SUBPOENA SHOULD ALSO BE QUASHED UNDER RULE 45 FOR FAILURE TO ALLOW A REASONABLE TIME FOR COMPLIANCE AND IMPOSING AN UNDUE BURDEN ..........…
…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…
…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…
…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…
…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…
…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…
…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…
…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…
…unproven statements in the form of unanswered questions, serves only one purpose which is to confuse the jury by claiming that the failure to answer the questions must mean the answer is harmful to both Mr. Epstein and to Ms…
…TAV was negligent in the design, manufacture and supply of the switch that failed to operate, a failure which caused or contributed to the incident. The switch manufactured by TAV was fitted by MCS. It was designed to be triggered…
…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…
…Respondents may have an action for breach of contract against [petitioner] for its alleged failure to adhere to its obligations under the confidentiality agreement—the Court makes no finding whatsoever on that question.”). 7 Case 1:15-cv-07433…