…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…
…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…
…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…
…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…
…Does 55 & 56 Reply Objs. 3, their citation is incomplete. The Amodeo court reasoned that: In determining the weight to be accorded an assertion of a right of privacy, courts should first consider the degree to which the subject matter…
…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…
…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…
…to determine something to be 22 confidential, and then it could be challenged later. 23 And then subsequently after, it looked to us from an 24 incomplete view of the record, 35 motions, the Court said that 25 basically the…
…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) …
…Ex. M. A court may reopen a deposition if the changes to the transcript are made without adequate reasons, or if they are so substantial as to render the transcript incomplete or useless. See Hlinko, 1997 WL 68563, at*1…
…F, at 41:5-18 (emphasis supplied). An admittedly incomplete and incorrect cannot serve as the “best evidence” of anything. Second, the in dramatic respects from her CVRA joinder motion. In the Joinder Motion, Plaintiff alleged she was trafficked “to…
…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…
…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…
…402 and 403, any admission of this incomplete deposition would be improper. 16 Case 1:15-cv-07433-LAP Document 1331-7 Filed 01/05/24 Page 19 of 21 Like Mr. Rodriguez was expansively questioned based on counsel…
…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…
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