…information withheld is critically important ........................................................... 15 2. Ms. Maxwell would require an extension of the discovery period ................................ 17 II. STRIKING CLAIMS FOR MEDICAL AND EMOTIONAL DISTRESS DAMAGES IS CONSISTENT WITH THE PURPOSE OF R…
…information withheld is critically important ........................................................... 15 2. Ms. Maxwell would require an extension of the discovery period ................................ 17 II. STRIKING CLAIMS FOR MEDICAL AND EMOTIONAL DISTRESS DAMAGES IS CONSISTENT WITH THE PURPOSE OF R…
…information withheld is critically important ........................................................... 15 2. Ms. Maxwell would require an extension of the discovery period ................................ 17 II. STRIKING CLAIMS FOR MEDICAL AND EMOTIONAL DISTRESS DAMAGES IS CONSISTENT WITH THE PURPOSE OF R…
…information withheld is critically important ........................................................... 15 2. Ms. Maxwell would require an extension of the discovery period ................................ 17 II. STRIKING CLAIMS FOR MEDICAL AND EMOTIONAL DISTRESS DAMAGES IS CONSISTENT WITH THE PURPOSE OF R…
…culpable state of mind’; and (3) that the missing evidence is ‘relevant’ to the party's claim or defense such that a reasonable trier of fact could find that it would support that claim or defense.” Id. (citing Residential Funding…
…the first account, was forensically searched on its server using the search terms proposed by Defendants and as required by the Court. The search uncovered no responsive documents from any time period. See DE 320. This included both emails in…
…she used while she was with Epstein, and therefore, the one she used during the time period Defendant was abusing Ms. Giuffre. Defendant does not appear to have pursued access to this account very far. This inaction lies in stark…
…she used while she was with Epstein, and therefore, the one she used during the time period Defendant was abusing Ms. Giuffre. Defendant does not appear to have pursued access to this account very far. This inaction lies in stark…
…is desperately trying to manufacture baseless objections in an attempt to avoid going forward with the deposition. To date, despite this Court’s order overruling Defendant’s objections on time period, Defendant has produced only two documents to Ms. Giuffre…
…or any of her attorneys, agents, investigators, from the period 1999-present. 2. All fee agreements for Your engagements with any attorneys for the purpose of pursuing any civil or criminal claims regarding Jeffrey Epstein, Ghislaine Maxwell, 29. A copy…
…she used while she was with Epstein, and therefore, the one she used during the time period Defendant was abusing Ms. Giuffre. Defendant does not appear to have pursued access to this account very far. This inaction lies in stark…
…Giuffre and her attorneys going to “great lengths” to track down records; they have only responded to requests for doctor’s records when the defense has brought to their attention missing doctors and records. Jane Doe 2 Given Plaintiff’s…
…2d 69 (2d Cir.1991), the comt denied the n10tion to reopen discovery and granted summary judgment because the plaintiff fai led to seek any discovery during the six-month discovery period set forth by the court. In stark contrast…
…no evidence of having evidentiary value whatsoever. Significantly, there is no evidence that the dream journal became missing after she had a duty to preserve it, and Defendant has made no showing that Ms. Giuffre had this dream journal in…
…or any of her attorneys, agents, investigators, from the period 1999-present. 2. All fee agreements for Your engagements with any attorneys for the purpose of pursuing any civil or criminal claims regarding Jeffrey Epstein, Ghislaine Maxwell, Natalya Malyshov, Sarah…
…In other words, if you were A. I provided every single photograph that I have. messing around with Simona at this time and there’s a photo of Simona that you have, did you provide that? Ransome 02/17/17…
…hi other words, if you were A. I provided every single photograph that I have. messing around with Simona at this time and there's a photo of Simona that you have, did you provide that? Ransome 02/17/17…
… Ex. A (correspondence between Chambers and Plaintiff’s counsel stating: “I just want to make sure that there is nothing MISSING from the Binder that the Judge needs to rule on”). The Court’s review of these materials makes clear…
…There can be no excuse for failure to do so and no excuse for continuing to refuse to disclose all of her email accounts. B. Substantial Data is Missing from the Defendant. Significant data is missing from the Defendant. Tellingly…
…the transcript is confidential, a fortiori Ms. Schultz’s designation of the vast majority of it as confidential is objectionable under Paragraph 11 of the Protective Order. Two things are missing from the letter motion. Ms. Schultz fails to explain…