…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…
…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…
…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…
…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…
…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…
…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…
…Cernovich does not come close to making that demanding showing. Cernovich’s failure to make that showing stands out in sharp relief when he argues that the “privacy concerns” of third-parties who are protected by the Court’s Protective…
…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…
…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…
…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…
…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…
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