…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…
…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…
…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…
…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…
…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)…
…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…
…The pendency of various motions and the uncompleted and outstanding discovery issues have impacted the ability of the parties to complete fact discovery and the endorsement of expert witnesses. The parties anticipate that there will be a significant number of…
…had some remarkable memory lapses during earlier depositions, feigned incomprehension of common words such as “puppet,” as well as repeatedly requesting that questions be re-asked or clarified, over and over and over again, when the those questions were clear…
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