…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…
…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…
…they would take a screenshot 14 of a part of an e-mail. Another one would be hidden in the 15 screenshot and another one would be disclosed. So there are 16 obviously e-mails that are responsive to our…
…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…
…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…
…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…
…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…
…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…
…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…