…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…
…An English Court has since ordered Gow to sit for his deposition, despite Defendant and her counsel’s obstructionist refusal to produce him prior to that litigation. Second, these documents are relevant precisely for the reason Defendant attempts to say…
…as Confidential at this time. 1 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…
…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…
…pleads guilty on March 18th, 2010, to obstruction of SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 Case 1:15-cv-07433-LAP Document 824 Filed 04/03/17 Page 28 of 47 28 H3GVGIUC 1 justice. On the…
…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…
…sanctions by complying once caught in her improper conduct. “The sanctions imposed by Rule 37 for obstructing or failing to comply with discovery procedures would be hollow indeed if they could be imposed only on those whose efforts at concealment…
…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…
…An English Court has since ordered Gow to sit for his deposition, despite Defendant and her counsel’s obstructionist refusal to produce him prior to that litigation. Second, these documents are relevant precisely for the reason Defendant attempts to say…
…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…
…of Defendant’s electronic data to ensure compliance with this Court’s Order. In addition, in view of the pattern of obstructive behavior, the Court should give to the jury an adverse inference instruction. October 28, 2016 8 For example…
…is still hiding. “The sanctions imposed by Rule 37 for obstructing or failing to comply with discovery procedures would be hollow indeed if they could be imposed only on those whose efforts at concealment proved to be successful. Plaintiff may…
…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…
…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…