…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…
…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…
…The public’s interest in this litigation, which involved voluminous documents and testimony about Epstein’s transcontinental sex-trafficking operation and the failures of the criminal justice system, cannot be understated or confined to Maxwell’s narrow definition of “monitoring…
…D. at 64 (E.D.N.Y. 2012) (internal citations and quotations omitted) (denying motion to lift 21 confidentiality of report of policing failures surrounding the murder of a young mother). “Consequently, in a major decision in this field, Martindell…
…VIRGINIA L. GIUFFRE, Plaintiff, v. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. --------------------------------------------------X DEFENDANT’S MOTION FOR RULE 37(b) &(c) SANCTIONS FOR FAILURE TO COMPL…
…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…
…3) and 26(g)(3). I. PRELIMINARY STATEMENT This discovery motion arises from Plaintiff’s failure and refusal to provide information that she has put at issue in this case. Plaintiff broadly published statements in public court filings and in…
…Y. 2012) (internal citations and quota t ions omitted) (denying motion to lift confidentiality of report of polic in g failures surrounding the murder of a young mother) . "It is presumptively unfair for courts to modify protecti v e orders…
…VIRGINIA L. GIUFFRE, Plaintiff, v. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. --------------------------------------------------X DEFENDANT’S MOTION FOR RULE 37(b) &(c) SANCTIONS FOR FAILURE TO COMPL…
…OF SIGRID S. MCCAWLEY IN 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 RUILE 26(a) I, Sigrid S…
…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)…
…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…
…OF SIGRID S. MCCAWLEY IN 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 RUILE 26(a) I, Sigrid S…
…Avenue Denver, CO 80203 303.831.7364 TABLE OF CONTENTS INTRODUCTION ..............................................…
…OF SIGRID S. MCCAWLEY IN 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 RUILE 26(a) I, Sigrid S…
…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…
…this Reply in support of her motion for 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 the Court’s Protective Order. …
…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 …
…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…
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