…Giuffre has been diligently attempting to depose Mr. Gow and it is only because of his obstructionism (apparently coordinated with Defendant) that his deposition has not been taken. Allowing a short extension of time to permit international process to be…
…1993) (internal citations omitted). The Defendant’s continued systemic foot-dragging and obstructionism – even following the Court’s June 20 Sealed Order and August 10, 2016 Order [DE 352] – makes an adverse inference instruction with regard to Defendant’s documents…
…1993) (internal citations omitted). The Defendant’s continued systemic foot-dragging and obstructionism – even following the Court’s June 20 Sealed Order and August 10, 2016 Order [DE 352] – makes an adverse inference instruction with regard to Defendant’s documents…
…12 Tr. at 168:18 - 181:24. It appears that Defendant’s misleading tally of questions posed to her includes all the times questions were repeated or needlessly re-worded due to her obstructionist deposition tactics. Indeed, Defendant, who claimed…
…May 27, 2016 e-mail Correspondence from Laura Menninger to Bradley Edwards. This obstruction of discovery by refusing to attend subpoenaed depositions that were noticed to her about one month ago on May 4, 2016 should not be condoned. See…
…was itself an obvious lie. 13 The questions Defendant refused to answer fall squarely within this Court’s earlier order. Defendant can have no legitimate basis for obstructing the search for truth by refusing to answer. The Court should…
…and in light of the defamation claim in this case, is so unfounded and obstructionist that it constitutes a violation of this Court’s Order, whether or not Defendant actually engaged in the “extraordinary and unreasonable” task of running the…
…1993) (internal citations omitted). The Defendant’s continued systemic foot-dragging and obstructionism – even following the Court’s June 20 Sealed Order and August 10, 2016 Order [DE 352] – makes an adverse inference instruction with regard to Defendant’s documents…
…was itself an obvious lie. 13 The questions Defendant refused to answer fall squarely within this Court’s earlier order. Defendant can have no legitimate basis for obstructing the search for truth by refusing to answer. The Court should…
…and in light of the defamation claim in this case, is so unfounded and obstructionist that it constitutes a violation of this Court’s Order, whether or not Defendant actually engaged in the “extraordinary and unreasonable” task of running the…
…12 Tr. at 168:18 - 181:24. It appears that Defendant’s misleading tally of questions posed to her includes all the times questions were repeated or needlessly re-worded due to her obstructionist deposition tactics. Indeed, Defendant, who claimed…
…production - long after the close of fact discovery - would be untimely and prejudicial. Accordingly, based on Defendant’s systematic foot-dragging and obstructionism during the entire discovery period, and based on the prejudice to Ms. Giuffre concerning the late production…
…01/05/24 Page 14 of 17 The questions Defendant refused to answer fall squarely within this Court’s earlier order. Defendant can have no legitimate basis for obstructing the search for truth by refusing to answer. The Court should…
…May 27, 2016 e-mail Correspondence from Laura Menninger to Bradley Edwards. This obstruction of discovery by refusing to attend subpoenaed depositions that were noticed to her about one month ago on May 4, 2016 should not be condoned. See…
…and in light of the defamation claim in this case, is so unfounded and obstructionist that it constitutes a violation of this Court’s Order, whether or not Defendant actually engaged in the “extraordinary and unreasonable” task of running the…
…complied with discovery obligations. As fully set forth in the Reply, a party cannot avoid the penalties of its own sanctionable conduct simply because the opposing party has been able to overcome some of the obstructionist tactics. Nittolo v. Brand…
…07/15/21 Page 14 of 17 The questions Defendant refused to answer fall squarely within this Court’s earlier order. Defendant can have no legitimate basis for obstructing the search for truth by refusing to answer. The Court should…
…to civil causes of action under 18 U.S.C. $ 1595. 6t. Defendants additionally profited from the sex haffrcking of Plaintiff; obstnrcted investigations of the violations; atterrpted and conspired to violate, and succeeded in violating, 18 U.S.C…
…May 27, 2016 e-mail Correspondence from Laura Menninger to Bradley Edwards. This obstruction of discovery by refusing to attend subpoenaed depositions that were noticed to her about one month ago on May 4, 2016 should not be condoned. See…
…12 Tr. at 168:18 - 181:24. It appears that Defendant’s misleading tally of questions posed to her includes all the times questions were repeated or needlessly re-worded due to her obstructionist deposition tactics. Indeed, Defendant, who claimed…