…1990s and early 2000s, Plaintiff’s substantial substance abuse, her lack of credibility, her failures of memory and her selective use of law enforcement. Regarding the year 2015, the police reports demonstrate Plaintiff’s tumultuous home life, bearing no relationship…
…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…
…1990s and early 2000s, Plaintiff’s substantial substance abuse, her lack of credibility, her failures of memory and her selective use of law enforcement. Regarding the year 2015, the police reports demonstrate Plaintiff’s tumultuous home life, bearing no relationship…
…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…
…Indeed, Plaintiff’s second deposition still cannot be 8 Case 1:15-cv-07433-LAP Document 1330-17 Filed 01/05/24 Page 10 of 12 - scheduled because Plaintiff persists in her failures …
…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…
…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…
…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…
…the 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, …
…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…
…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…
…Walls v. Paulson, 250 F.R.D. 48 (D.D.C. 2008) (sanctioning Plaintiff for failure to sign interrogatories) (internal citations omitted). 5 Plaintiff refused to answer at all Interrogatory Nos. 5-14. Id. at 10-17. With respect…
…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…
…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…
…Plaintiff, v. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. --------------------------------------------------X DEFENDANT’S REPLY IN SUPPORT OF MOTION FOR RULE 37(b) &(c) SANCTIONS FOR FAILURE TO COM…
…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…
…Plaintiff, v. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. --------------------------------------------------X DEFENDANT’S REPLY IN SUPPORT OF MOTION FOR RULE 37(b) &(c) SANCTIONS FOR FAILURE TO…
…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…
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