…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…
…Case 1:15-cv-07433-LAP Document 1137-16 Filed 10/22/20 Page 2 of 15 TABLE OF CONTENTS Page I. THE PROPOSED DEPOSITIONS ARE IMPORTANT TO THE FUNDAMENTAL CLAIMS AND DEFEN…
…E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 TABLE OF CONTENTS Page I. THE PROPOSED DEPOSI…
…Case 1:15-cv-07433-LAP Document 1320-21 Filed 01/03/24 Page 2 of 15 TABLE OF CONTENTS Page I. THE PROPOSED DEPOSITIONS ARE IMPORTANT TO THE FUNDAMENTAL CLAIMS AND DEFEN…
…8 Brink’s Inc. v. City of New York, 717 F.2d 700 (2d Cir. 1983)........................................................................................................ 8 Cerro Gordo Charity v. Fireman’s Fund Am. Life Ins. Co., 819 F.2d 1471 (8th Cir. 1987) .........................................................................…
…Case 1:15-cv-07433-LAP Document 1137-17 Filed 10/22/20 Page 3 of 16 TABLE OF CONTENTS Page I. THE PROPOSED DEPOSITIONS ARE IMPORTANT TO THE FUNDAMENTAL CLAIMS AND DEFEN…
…Case 1:15-cv-07433-LAP Document 1137-18 Filed 10/22/20 Page 3 of 15 TABLE OF CONTENTS Page I. THE PROPOSED DEPOSITIONS ARE IMPORTANT TO THE FUNDAMENTAL CLAIMS AND DEFEN…
…16 Filed 01/05/24 Page 3 of 10 Plaintiff’s misplaced argument that Ms. Maxwell is somehow required to make Dr. Esplin available at trial violates the fundamental rules of trial and the requirements for rebuttal witnesses. Of course…
…presumption of access. Id.at 47 n. 13. (“Examples of such countervailing values may include, depending on the circumstances, preserving ‘the right of an accused to fundamental fairness in the jury selection process . . .’”) (quoting Press-Enter. Co., supra, 464 U…
…. . has to say about all this.” Motion to Present Epstein Testimony at 14. There is no indication in Cerro Gordo Charity v. Fireman's Fund Am. Life Ins. Co., 819 F.2d 1471 (8th Cir. 1987), on which plaintiff relies…
…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)…
…release-1c7caf33ced3db9ea7f4a81e5e114fb8 130 https://www.dailymail.co.uk/news/article-8911449/Two-Jeffrey-Epstein-accusers-drop-cases-suggesting-paid-compensation-fund.html 131 https://www.thedailybeast.com/ghislaine-maxwell-deposition-discussing-her-sex-life-and-jeffrey-epstein-ordered-released-thursday…
…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…
…Civ. P. 37(e)(2). The new Rule 37 “rejects cases such as Residential Funding Corp. v. DeGeorge Financial Corp., 306 F.3d 99 8 Case 1:15-cv-07433-LAP Document 1330-16 Filed 01/05/24 Page…
…however, that ‘the right of an accused to fundamental fairness in the jury selection process’ may be a countervailing interest that weighs against public access to documents.”); 5-6 (“The public’s First Amendment right of access to these documents…
…period 1999-present. RESPONSE: In addition to the Preliminary Statement and General Objections, Ransome objects to this request in that she is a non-party and this requests seeks fundamentally privileged communications between a non-party and her counsel. Specifically…
…period 1999-present. RESPONSE: In addition to the Preliminary Statement and General Objections, Ransome objects to this request in that she is a non-party and this requests seeks fundamentally privileged communications between a non-party and her counsel. Specifically…
…18 state of mind; and (3) that the destroyed evidence was 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. Residential Funding Corp. v…
…period 1999-present. RESPONSE: In addition to the Preliminary Statement and General Objections, Ransome objects to this request in that she is a non-party and this requests seeks fundamentally privileged communications between a non-party and her counsel. Specifically…