…days earlier. Plaintiff’s Response is devoted to (a) extraneous, irrelevant and selective quotations from witnesses who know nothing about her medical records or treatment,1 and (b) incomplete and inaccurate representations that she has, since the Court’s Order…
…robust” production, in fact she produced 18 pages of documents (three after the Motion to Compel was filed), an incomplete copy of one of her old passports, and 150 photographs which were given to her by In short, the Opposition…
…robust” production, in fact she produced 18 pages of documents (three after the Motion to Compel was filed), an incomplete copy of one of her old passports, and 150 photographs which were given to her by Jean Luc Brunel. In…
…Yet, Plaintiff has never supplemented her discovery responses to include these health care providers. Plaintiff has also failed to provide records, or has provided incomplete records, of several of the health care professionals, both disclosed and newly discovered, despite her…
…Yet, Plaintiff has never supplemented her discovery responses to include these health care providers. Plaintiff has also failed to provide records, or has provided incomplete records, of several of the health care professionals, both disclosed and newly discovered, despite her…
…Obtaining Discovery ....................................................................................................... 14 B. Plaintiff Refuses To Provide Her Residence, Domicile And Address Where She Lived During Alleged “Defamation.” ...................................................................... 15 C. Plaintiff…
…Yet, Plaintiff has never supplemented her discovery responses to include these health care providers. Plaintiff has also failed to provide records, or has provided incomplete records, of several of the health care professionals, both disclosed and newly discovered, despite her…
…May 3 Plaintiff’s Response is devoted to (a) extraneous, irrelevant and selective quotations from witnesses who know nothing about her medical records or treatment,1 and (b) incomplete and inaccurate representations that she has, since the Court’s Order…
…and proper discovery, through their own self-serving definition of “responsiveness.” As set forth in Dershowitz’s Motion to Compel, Plaintiffs’ interrogatory responses and document production are incomplete, with no date certain as to when they will be completed. Moreover,…
…of an address book containing Dershowitz's name and contact information which an Epstein associate characterized as "the Holy Grail;" and (7) Numerous demonstrably incomplete flight manifests showing that Jane Doe No. 3 was transported on Epstein's private plane…
…19 3. Plaintiff’s compensation for selling information ........................................................... 20 4. “Defamatory” actions by others is relevant.................................................................... 20 D. Plaintiff’s incomplete and evasive answers are improper. .......................…
…Yet, Plaintiff has never supplemented her discovery responses to include these health care providers. Plaintiff has also failed to provide records, or has provided incomplete records, of several of the health care professionals, both disclosed and newly discovered, despite her…
…the other issues are 8 addressed in our papers. We have highlighted her incomplete 9 production on several fronts and her refusal to answer any 10 interrogatories. So I would rest on my papers with respect to 11 the other…
…the false statements to be issued to various media outlets. Ms. Giuffre has not had the opportunity to depose Maxwell’s agent Ross Gow; therefore, this answer remains incomplete. Consequently, Ms. Giuffre reserves the right to modify and/or supplement…
…16- 268, Disc 7 at p. 2305 (GIUFFRE007843) Because of Defendant’s refusal to search this important email account, any production yielded from any search terms will necessarily be incomplete. Indeed, this failure is particularly prejudicial, as this account appears…
…7, and 8, as discussed below, the productions are incomplete and an unknown volume of documents have been withheld. Having purposefully interjected herself into this litigation, and initiating another litigation based on the same allegations about which she now plans…
…Ransome in the deposition in this case. For this reason, the deposition transcript standing alone leaves an incomplete and, thus, false impression of Ms. Ransome and her outrageous claims. This Court should not allow its power to enter and modify…
…documents “in a timely manner if the party learns that in some material respect the disclosure or response is incorrect and incomplete.” “The duty to supplement and correct disclosures and responses is a continuing duty and no motion to compel…
…See Fed. R. Civ. P. 37(a)(3) (“[A]n evasive or incomplete disclosure, answer, or response shall be deemed a failure to disclose, answer, or respond.”). Moreover, Plaintiff failed to identify any healthcare providers who have treated her for…
…documents over the course of a month but (b) keep Ms. Maxwell’s deposition on March 25, 2016, despite her incomplete and untimely production, and incorrectly stating that Ms. Maxwell had demanded she “cancel” her deposition. (Doc. # 59 at 3) …
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