…s accountability and legitimacy.” No. 14-CV-6867 (VEC), 2016 WL 1071107, at *9. “And the public has a right to know how its resources are being used—courts are funded by the public, . . . and the laws under which parties…
…Motion for Sanctions (“Sur-Reply”), stating as follows: INTRODUCTION Plaintiff’s Response and Sur-Reply are founded entirely on a miscomprehension of the requirements of Federal Rules of Civil Procedure 26 and 33. She strenuously argues that she has “disclosed…
…Motion for Sanctions (“Sur-Reply”), stating as follows: INTRODUCTION Plaintiff’s Response and Sur-Reply are founded entirely on a miscomprehension of the requirements of Federal Rules of Civil Procedure 26 and 33. She strenuously argues that she has “disclosed…
…RWS Document 22 Filed 12/15/15 Page 2 of 14 Table of Contents ARGUMENT....................................................................................................................... 2 I. The Motion to Dismiss is Dispositive and Well Founded In Law ....................…
…present in her case-in-chief. Ms. Maxwell has filed well-founded motions in limine to exclude the testimony of both Dr. Kliman and Professor Coonan prohibiting from providing their credibility and vouching opinions. This is the subject matter of…
…1285 at 2. However, any assumptions the Court made were well founded, and the Court’s ultimate ruling was correct and should not be reconsidered. Doe 171’s motion asserts that she “maintains her right to remain anonymous,” yet her…
…do acknowledge that the public filing in the Crime Victims’ Rights Act case of their client’s allegation against Defendant Dershowitz became a major distraction from the merits of the well-founded Crime Victims’ Rights Act by causing delay and…
…The Terramar Project, that Ms. Maxwell founded and runs. Plaintiff’s originally proposed terms also failed to relate to the actual discovery requests upon which they were to be based. For search terms 124-341, Plaintiff took her own Rule…
…their client’s claims – were false. The Complaint by Edwards and Cassell alleged that “[i]mmediately following the filing of what Dershowitz knew to be an entirely proper and well- founded pleading, Dershowitz initiated a massive public media assault on…
…their client’s claims – were false. The Complaint by Edwards and Cassell alleged that “[i]mmediately following the filing of what Dershowitz knew to be an entirely proper and well- founded pleading, Dershowitz initiated a massive public media assault on…
…Thus, the notion that Churcher may be compelled to testify simply because she “observed” firsthand some of the events about which Maxwell is inquiring in this civil case is not well founded. In any event, the various accusations of Churcher…
…do acknowledge that the public filing in the Crime Victims' Rights Act case of their client's allegation against Defendant Dershowitz became a major distraction from the merits of the well-founded Crime Victims' Rights Act by causing delay and…
…CONCLUSION As detailed above, good cause exists to justify a stay of discovery pending Ms. Maxwell’s motion to dismiss. The motion is dispositive and well founded in law, the stay is of short duration, and the expected discovery is…
…Thus, the notion that Churcher may be compelled to testify simply because she “observed” firsthand some of the events about which Maxwell is inquiring in this civil case is not well founded. In any event, the various accusations of Churcher…
…do acknowledge that the public filing in the Crime Victims’ Rights Act case of their client’s allegation against Defendant Dershowitz became a major distraction from the merits of the well-founded Crime Victims’ Rights Act by causing delay and…
…from testifying at trial. Taylor is not properly qualified as an expert on some subjects that he plan to testify about, his testimony is not well-founded on reliable principles, will not be helpful to the jury, and is prejudicial…
…Thus, the notion that Churcher may be compelled to testify simply because she “observed” firsthand some of the events about which Maxwell is inquiring in this civil case is not well founded. In any event, the various accusations of Churcher…
…The Terramar Project, that Ms. Maxwell founded and runs. Plaintiff’s originally proposed terms also failed to relate to the actual discovery requests upon which they were to be based. For search terms 124-341, Plaintiff took her own Rule…
…any investigation of the credibility of the accusations, and of having acted unethically …” – even though Dershowitz “knew [the filing in the Federal Action containing the allegations about Dershowitz] to be an entirely proper and well-founded pleading.” See Compl. …
…simply too tangential and remote to be relevant even under the most broad definitions of relevance. Accordingly, Ms. Maxwell’s objection is well founded and should be sustained by the Court. II. MS. MAXWELL’S SPECIFIC OBJECTIONS ARE PROPER Ms…
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