…false allegations that she was sexually abused by Ms. Maxwell. Plaintiff spends the remainder of her opposition selectively misunderstanding applicable federal and New York state defamation law. When correctly applying the law, it is clear that there are ample grounds…
…they are disclosed for the first time now. The Court’s Order also appears to be based on certain misunderstandings of fact that Doe 171’s undersigned counsel are currently investigating. In short, Doe 171 does not intend to impose…
…13 this matter has been resolved. 14 MS. McCAWLEY: Your Honor, I think there was a 15 misunderstanding with respect -- 16 THE COURT: I was sure. 17 MS. McCAWLEY: Dr. Olsen has been noticed for 18 deposition in Colorado already…
…d) of the Protocol. Here, the ambiguity in the September 25 Email may be the product of Does 1 and 2 misunderstanding the process provided by the Protocol, which to those unrepresented by counsel may understandably appear dense and convoluted. …
…of the parties; but, it was clearly just that – a miscommunication and misunderstanding on where things stood. 4 with anyone that Plaintiff believed was or might be a witness, although no discovery requests called for such communications. Consequently, during the…
… but, it was clearly just that – a miscommunication and misunderstanding on where things stood. 4 Case 1:15-cv-07433-LAP Document 1327-12 Filed 01/05/24 Page 6 of 11 tremendous stretch, I can agree to them…
…it was clearly just that – a miscommunication and misunderstanding on where things stood. 4 Case 1:15-cv-07433-LAP Document 1202-1 Filed 01/27/21 Page 6 of 11 Case 1:15-cv-07433-LAP Document 1202-1…
…SCHULTZ: Sorry, your Honor. No. I think that's 24 a misunderstanding. What they received "ten minutes before" 25 were clips of the video. The entire video was produced well in SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 …
…13 this matter has been resolved. 14 MS. McCAWLEY: Your Honor, I think there was a 15 misunderstanding with respect -- 16 THE COURT: I was sure. 17 MS. McCAWLEY: Dr. Olsen has been noticed for 18 deposition in Colorado already…
…SCHULTZ: Sorry, your Honor. No. I think that's 24 a misunderstanding. What they received "ten minutes before" 25 were clips of the video. The entire video was produced well in SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 …
…do not exist; a misreading of Ms. Maxwell’s response; or a misunderstanding of the facts or law. The Court should deny the Motion to Compel. ARGUMENT I. The objections and responses to the RFPs are proper. A. RFP No…
…it was clearly just that – a miscommunication and misunderstanding on where things stood. 4 Case 1:15-cv-07433-LAP Document 1202-1 Filed 01/27/21 Page 6 of 11 Case 1:15-cv-07433-LAP Document 1202-1…
…13 this matter has been resolved. 14 MS. McCAWLEY: Your Honor, I think there was a 15 misunderstanding with respect -- 16 THE COURT: I was sure. 17 MS. McCAWLEY: Dr. Olsen has been noticed for 18 deposition in Colorado already…
… but, it was clearly just that – a miscommunication and misunderstanding on where things stood. 4 Case 1:15-cv-07433-LAP Document 320 Filed 08/01/16 Page 6 of 11 tremendous stretch, I can agree to them in…
…13 this matter has been resolved. 14 MS. McCAWLEY: Your Honor, I think there was a 15 misunderstanding with respect -- 16 THE COURT: I was sure. 17 MS. McCAWLEY: Dr. Olsen has been noticed for 18 deposition in Colorado already…
…different metadata it must be produced. Defendant’s misguided argument that Plaintiff has artificially inflated the volume of her document production by producing “duplicate” documents reveals a misunderstanding of basic electronic discovery law and practices. Plaintiff utilized an electronic deduplication…
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