…are among the best records of Plaintiff’s lies. They are public documents and there is no good faith basis for Plaintiff’s attempt to render them hidden from public view, in her public lawsuit designed to promote her well…
…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…
…materials.” Brown, supra at 45. Although TGP is appreciative of the Court’s efforts to unseal since that decision, the most crucial information that the public is demanding to know remains hidden. Though it may be possible that, somehow, no…
…of 35 Page 106 1 sitting, and I believe Jeffrey took the photo. I 2 was just sitting on a couch upstairs in the 3 bathroom. 4 Q. It wasn't taken by a hidden camera? 5 A. No. No…
…discoverable, and was purposefully hidden by Plaintiff. Any action short of precluding claims for physical, psychological and emotional distress damages will fall short of serving Rule 37’s purpose to “ensure that a party will not benefit from its own…
…example, if Defendant were to testify at trial she had a net worth of only ten million dollars – and not provide information about where she had hidden the fifteen million dollars associated with the sale of her apartment – then Ms…
…Dr. Donahue. Additionally, Defendant acts in bad faith when she claims that medical records from Dr. Donahue were “purposefully hidden by Plaintiff” (Mtn. at 11) when Defendant knows that Ms. Giuffre executed and sent a medical release for Dr. Donahue…
…2016, Subpoenas to Churcher and Weissfeld. Yet, Defendant cited a number of cases wherein discovery was buried amid voluminous productions so as to be hidden or to cause delayed or cumbersome discovery of them. They are inapposite. Defendant didn’t…
… disclosed June 1 Shopper’s Paradise – subpoena notice April 26; never disclosed How many other witnesses are there with relevant information that Plaintiff has hidden? 5 No ruling had been made on this Motion. 12 Case 1:15…
…example, if Defendant were to testify at trial she had a net worth of only ten million dollars – and not provide information about where she had hidden the fifteen million dollars associated with the sale of her apartment – then Ms…
…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…
…result in an unmanageable number of documents. Instead, Defendant is picking and choosing which documents she will produce, and which documents she will keep hidden. She’s not making this determination based on responsiveness, or based on undue burden, but…
…Dr. Donahue. Additionally, Defendant acts in bad faith when she claims that medical records from Dr. Donahue were “purposefully hidden by Plaintiff” (Mtn. at 11) when Defendant knows that Ms. Giuffre executed and sent a medical release for Dr. Donahue…
…Dr. Donahue. Additionally, Defendant acts in bad faith when she claims that medical records from Dr. Donahue were “purposefully hidden by Plaintiff” (Mtn. at 11) when Defendant knows that Ms. Giuffre executed and sent a medical release for Dr. Donahue…
…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…
…discoverable, and was purposefully hidden by Plaintiff. Any action short of precluding claims for physical, psychological and emotional distress damages will fall short of serving Rule 37’s purpose to “ensure that a party will not benefit from its own…
…the practice of courts viewing such testimony as false and intentionally evasive, and as a sham or subterfuge that purposely avoids 17 deliberately “withheld” or “hidden” are things that Ms. Giuffre provided to Defendant in the normal course of discovery…
…could lead to the adjudication of this case. Due to all the redactions in the record, even the reasons for the Protective Order are hidden from the public. (ECF No. 39-1). Movant recognizes that this Court entered an order…
…cv-07433-LAP Document 1198-12 Filed 01/27/21 Page 22 of 30 Case 1:15-cv-07433-LAP Document 1198-12 Filed 01/27/21 Page 23 of 30 deliberately “withheld” or “hidden” are things that Ms…
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