…or intentionally destroyed evidence by burning, shredding, or wiping out computer hard drives.” Id. at 469–70 & n.48. ARGUMENT I. PLAINTIFF ADMITTED EACH ELEMENT OF INTENTIONAL SPOLIATION Plaintiff admitted at her depositions to each factor required for a finding…
…or intentionally destroying evidence by burning, shredding, or wiping out computer hard drives.”) (emphasis supplied). The motivation for the action is irrelevant. The purposeful nature and manner of the destruction is all that matters. 5 Because the act of…
…or intentionally destroying evidence by burning, shredding, or wiping out computer hard drives.”) (emphasis supplied). The motivation for the action is irrelevant. The purposeful nature and manner of the destruction is all that matters. 5 Because the act of…
…or intentionally destroyed evidence by burning, shredding, or wiping out computer hard drives." I Id. at 469- 70 & n.48. I ARGUMENT I I. PLAINTIFF ADMITTED EACH ELEMENT OF INTENTIONAL SPOLIATION Plaintiff admitted at her depositions to each factor required…
…relates to Doe 53 and Doe 151. Someone 18 is still not on mute. Yeah, you. How hard is this to make it 19 easier for the court reporter, my friends? 20 MR. KELLEHER: Your Honor, this is Denis Kelleher. …
…frankly, not every 22 recipient of these notices is the kind of person that has a 23 lawyer on speed dial. 24 We also think that it can be hard to -- communications 25 are more difficult now. So we certainly…
…reports of this case. Indeed, it is hard to conceive of an area more directly relevant to this single- count defamation case in which Ms. Maxwell has said that Plaintiff’s statements to the press were lies, and now even…
…18 probably log in and print it, to be honest. It 19 wouldn't be that hard. I assumed that the hospital 20 is taking care of all the documentation that was 21 requested. So I didn't actually bring…
…on June 28. Her claim that she could not “remember” Dr. Donohue or Judith Lightfoot until her deposition is hard to believe given she had consulted with them in the days and weeks just before her Interrogatory Responses. Id.; Ex…