…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…
…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…
…participate in and begin the discovery process. From the moment this case began, it appears that the Defendant’s goal has been obstruction and delay, with the apparent aim of avoiding discovery altogether. The Defendant’s opposition brief is the…
…¶ 8-11. Mr. Rodriguez subsequently was prosecuted and imprisoned for this bribery and obstruction scheme. These actions and conviction, which did not occur until after the deposition Plaintiff seeks to proffer, are quintessential character impeachment evidence that no one has…
…in pretrial discovery proceedings, that the matter is privileged.”). As the court in Hearn put it: In an ordinary case the obstruction is not likely to be great, for attorney-client communications are usually incidental to the lawsuit, notwithstanding their …
…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…
…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…