…Eleven months into this case, and after the close of fact discovery, Defendant continues to refuse to abide by her most basic and fundamental discovery obligations. A summary of this ongoing and willful non-compliance, as well as a supplement…
…Eleven months into this case, and after the close of fact discovery, Defendant continues to refuse to abide by her most basic and fundamental discovery obligations. A summary of this ongoing and willful non-compliance, as well as a supplement…
…Eleven months into this case, and after the close of fact discovery, Defendant continues to refuse to abide by her most basic and fundamental discovery obligations. A summary of this ongoing and willful non-compliance, as well as a supplement…
…an implied duty under the regulations to investigate, there was no duty to report; more fundamentally, it had not been established that Total was the operator of the site for the purpose of the COMAH Regulations. That E would be…
…TO PRECLUDE INTRODUCTION OF TESTIMONY FROM A WITNESS MS. GIUFFRE HAS NOT HAD THE OPPORTUNITY TO CROSS EXAMINE. ............................................................................8 A. Allowing Excerpts from the Dershowitz Deposition in the Florida Case Would be Fundam…
…Spin Master Ltd. v. Bureau Veritas Consumer Products Service, Inc., 2016 WL 690819 (W.D.N.Y., 2016) ....................................................................................... 30 T. Rowe Price Small-Cap Fund, Inc. v. Oppenheimer & Co., Inc., 174 F.R.D. 38 (S.D.N.Y. 1997)…
…Inc., 676 F.3d 83, 98 (2d Cir. 2012), quoting Trs. of Plumbers & Pipefitters Nat'l Pension Fund v. Transworld Mech., Inc., 886 F.Supp. 1134, 1139 (S.D.N.Y.1995). II. ARGUMENT Defendant first notes that she contacted…
…Not Warrant Continued Sealing. Finally, Maxwell cites the countervailing interest of “[p]reserving the fundamental rights of suspects or others under criminal investigation” as justifying complete sealing of any document containing portions or summaries of her deposition testimony. Maxwell Mem…
…same breath objects to the unsealing of the names of Does 1 and 2. This evinces a fundamental misunderstanding about the process at hand--after all, an objection by Does 1 and 2 to the release of their names is…
…insure their irrelevance.” United States v. Amodeo, 71 F.3d 1044, 1049 (2d Cir. 1995) (“Amodeo II”); United States v. All Funds on Deposit at Wells Fargo Bank, 643 F. Supp. 2d 577, 583 (S.D.N.Y. 2009). “Especially …
…mind’; and (3) that the missing evidence is ‘relevant’ to the party's claim or defense such that a reasonable trier of fact could find that it would support that claim or defense.” Id. (citing Residential Funding Corp. v. DeGeorge…
…mind’; and (3) that the missing evidence is ‘relevant’ to the party's claim or defense such that a reasonable trier of fact could find that it would support that claim or defense.” Id. (citing Residential Funding Corp. v. DeGeorge…
…mind’; and (3) that the missing evidence is ‘relevant’ to the party's claim or defense such that a reasonable trier of fact could find that it would support that claim or defense.” Id. citing Residential Funding Corp. v. DeGeorge…
…Kingdom.” Resp. at 3. This argument is fundamentally flawed for five reasons. First, the very news articles cited by Plaintiff document that the townhome had been on the market for sale for over a year - i.e., since at least…
…mind’; and (3) that the missing evidence is ‘relevant’ to the party's claim or defense such that a reasonable trier of fact could find that it would support that claim or defense.” Id. (citing Residential Funding Corp. v. DeGeorge…
…statements about various interactions with former-President Bill Clinton. Of course, if Defendant (or any of her organizations) is receiving funding from the Clinton Foundation, that would provide a clear motive for her to slant testimony on this subject. Ms…
…mind’; and (3) that the missing evidence is ‘relevant’ to the party's claim or defense such that a reasonable trier of fact could find that it would support that claim or defense.” Id. (citing Residential Funding Corp. v. DeGeorge…
…mind’; and (3) that the missing evidence is ‘relevant’ to the party's claim or defense such that a reasonable trier of fact could find that it would support that claim or defense.” Id. citing Residential Funding Corp. v. DeGeorge…