…the Court’s order, Ms. Giuffre effected alternative service of a subpoena to testify at a deposition on Ms. Kellen in multiple ways, all calculated to give her actual notice of the subpoena. See Schultz Decl. at Composite Exhibit 1…
…Comply with Rule 26(a), stating as follows: CERTIFICATE OF CONFERRAL The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an attempt to obtain records and interrogatory responses Ordered by the Court, including by letter dated April…
…Comply with Rule 26(a), stating as follows: CERTIFICATE OF CONFERRAL The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an attempt to obtain records and interrogatory responses Ordered by the Court, including by letter dated April…
…Comply with Rule 26(a), stating as follows: CERTIFICATE OF CONFERRAL The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an attempt to obtain records and interrogatory responses Ordered by the Court, including by letter dated April…
…Comply with Rule 26(a), stating as follows: CERTIFICATE OF CONFERRAL The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an attempt to obtain records and interrogatory responses Ordered by the Court, including by letter dated April…
…Repeated Disregard for this Court’s Order Supports An Adverse Inference Ms. Giuffre does not want to burden the Court with unnecessary briefing on a topic that has been argued multiple times. See Docket Entry 96 (Motion for Forensic Examination)…
…that embedded terms are located. (Wildcard characters are used to expand word searches into pattern searches by “replacing” single or multiple characters.) Where there are a specific number of characters needed to be included, a single wildcard will achieve that…
…as to each document for ease of reference. In future oppositions to objections to unsealing, Plaintiff will refer back to relevant portions of this brief instead of re-briefing issues multiple times. Further, Plaintiff files this brief with the same…
…Defendant’s documents concerning Ms. Giuffre are directly relevant to this action, particularly because Defendant has created multiple drafts of statements to the press defaming Ms. Giuffre. Throughout the months of motion practice concerning these issues, and throughout all of…
…Defendant’s documents concerning Ms. Giuffre are directly relevant to this action, particularly because Defendant has created multiple drafts of statements to the press defaming Ms. Giuffre. Throughout the months of motion practice concerning these issues, and throughout all of…
…Defendant’s documents concerning Ms. Giuffre are directly relevant to this action, particularly because Defendant has created multiple drafts of statements to the press defaming Ms. Giuffre. Throughout the months of motion practice concerning these issues, and throughout all of…
…here that even Defendant has to ultimately concede that discovery about her financial information is relevant to this case. II. DISCUSSION Because discovery regarding Defendant’s financial circumstances and recent transactions is relevant to this case for multiple reasons, Ms…
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