…Accordingly, not only did Defendant improperly withhold these documents, she also improperly failed to disclose them on her privilege log. They were simply hidden. 3 The Requests to which these documents are responsive include, but are not limited to, Ms…
…all emails—whether saved or deleted – and irrespective of which account they came from; not a single responsive email was located from any Mindspring account and no emails were located from Earthlink or any other secret, hidden, “undisclosed” email account…
…all emails—whether saved or deleted – and irrespective of which account they came from; not a single responsive email was located - from any Mindspring account and no emails were located from Earthlink or any other secret, hidden, “undisclosed” email account…
…to relevant discovery. 7 Case 1:15-cv-07433-LAP Document 230 Filed 06/20/16 Page 11 of 19 It is completely unknown what other relevant and probative information will be uncovered in Plaintiff’s previously hidden accounts…
…s Order Continued conferral by Ms. Giuffre’s counsel regarding the hidden email accounts was unavailing. An adverse inference instruction is appropriate when a party refuses to turn over documents in defiance of a Court Order. See Lyondell-Citgo Refining…
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