…Obtaining Discovery ....................................................................................................... 14 B. Plaintiff Refuses To Provide Her Residence, Domicile And Address Where She Lived During Alleged “Defamation.” ...................................................................... 15 C. Plaintiff…
…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. .......................…
…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…
…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…
…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…
…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 her responses, as information is largely in the possession of…
…F, at 41:5-18 (emphasis supplied). An admittedly incomplete and incorrect “manuscript” cannot serve as the “best evidence” of anything. Second, the book manuscript differs in dramatic respects from her CVRA joinder motion. In the Joinder Motion, Plaintiff alleged…
…log production parameters unless Ms. Giuffre agrees to cancel the most critical deposition in this case – that of the Defendant. 3 These numbers are based only upon the partial and incomplete flight logs available to Ms. Giuffre at this time…
…Id. B. Plaintiff’s Counsel Has Repeatedly and Publicly Filed In This Case Numerous Publicly Available Police Reports With Redacted Juvenile Information In complete contradiction to her legal position in this Motion, Plaintiff and her counsel have repeatedly filed in…
…LAP Document 1295-2 Filed 12/12/22 Page 5 of 12 times. She also spent much of her time feigning incomprehension of simple sentences and common words, also causing the same question to be posed to her multiple times…
…LAP Document 1201-17 Filed 01/27/21 Page 5 of 12 times. She also spent much of her time feigning incomprehension of simple sentences and common words, also causing the same question to be posed to her multiple times…
…No. 08-CV-6147L, 2011 WL 839739, at *2 (W.D.N.Y. Mar. 7, 2011) (denying motion to compel where “the interrogatory [was] otherwise incomprehensible”), cited with approval in Denim Habit, LLC v. NJC Boston, LLC, No. 13CV6084ADSSIL, 2016…
…LAP Document 1328-7 Filed 01/05/24 Page 5 of 12 times. She also spent much of her time feigning incomprehension of simple sentences and common words, also causing the same question to be posed to her multiple times…
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