…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…
…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…
…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…
…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…
…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…
…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…
…that is vital to his defense – the third prong in the tri-part test. To date, Plaintiffs have hidden behind the attorney-client privilege to selectively produce evidence regarding their conversations, emails, and/or interviews with Giuffre. As noted above…
…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…
…in fact, haven't you read many of 8 these newspaper articles? 9 A. That is correct. 10 Q. That was not a hidden secret from the 11 public beginning in 2006, right? 12 A. No. 13 Q. And from…
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