…For other providers, no records were produced. Where no documents were produced, Plaintiff failed to identify the dates and nature of the treatment received, as requested in the Interrogatory. Id. Plaintiff failed therein to identify any treatment providers prior to…
…each category of damages claimed by the disclosing party—who must also make available for inspection and copying as under Rule 34 the documents or other evidentiary material, unless privileged or protected from disclosure, on which each computation is based…
…For other providers, no records were produced. Where no documents were produced, Plaintiff failed to identify the dates and nature of the treatment received, as requested in the Interrogatory. Id. Plaintiff failed therein to identify any treatment providers prior to…
…For other providers, no records were produced. Where no documents were produced, Plaintiff failed to identify the dates and nature of the treatment received, as requested in the Interrogatory. Id. Plaintiff failed therein to identify any treatment providers prior to…
…of previous public access to the documents; (3) the fact that someone has objected to disclosure, and the identity of that person; (4) the strength of any property and privacy interests asserted; (5) the possibility of prejudice to those opposing …
…to the Protocol.” Maxwell Mem. at 14–15. In light of Maxwell’s failure to identify any reason to keep 4 Maxwell also contends that the following docket entries should remain under seal: 144-3, 153, 153-2, 153-3…
…2016, 7:02 p.m., Letter from Ty Gee to Ms. Schultz (refusing to run Ms. Giuffre’s name as a search term as part of effort to identify responsive documents). Specifically, Mr. Gee’s letter said that such a…
…Giuffre of any practical ability to use the discovery, and, importantly, it was incumbent on Defendant to identify this account. The Second Circuit has stated, “[w]here documents, witnesses, or information of any kind relevant issues in litigation is or…
…2016, 7:02 p.m., Letter from Ty Gee to Ms. Schultz (refusing to run Ms. Giuffre’s name as a search term as part of effort to identify responsive documents). Specifically, Mr. Gee’s letter said that such a…
…2016, 7:02 p.m., Letter from Ty Gee to Ms. Schultz (refusing to run Ms. Giuffre’s name as a search term as part of effort to identify responsive documents). Specifically, Mr. Gee’s letter said that such a…
…statements, the discovery here should be much broader – and should include all of the significant requests made by Ms. Giuffre. For example, Defendant should also be required to identify all financial transactions involving (directly or indirectly) Jeffrey Epstein, , Ellmax LLC…
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