…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…
…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…
…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…
…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…
…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…
…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…
…2d. 323, 336 (S.D.N.Y. 2010) (absence of “facts to support the inference that [the subject] statement imputed incompetence, incapacity or unfitness in the performance of [her] profession” as a bookkeeper warranted dismissal of defamation per se claim)…