…26(a)(1)(B).2 B. Plaintiff Cannot Base Her Purported Damages for Non-Economic Damages on the Outcome of the Cases of Other People. Accordingly, the Disclosure Violates Rule 26 2 Plaintiff’s counsel advised undersigned counsel that she…
…titled, M10- 468- In re Pilot Project Regarding Case Management Techniques for Complex Civil Cases in the Southern District of New York. Pl’s Motion at 9. On the other hand, in her Opposition to Defendant’s Motion to Stay…
…force to all federal civil cases, regardless of the subject matter. In addition to the requirements stated plainly in Fed. R. Civ. P. 26, and in addition to case law from the this Court and others courts within the Southern…
…RESEARCH CENTER, June 26, 2015. Additionally, her boyfriend, Jeffrey Epstein, with whom she shared a household from 1999-2002 (and other years), implemented an entire, private email system to communicate with his household and employees, including Defendant. Accordingly, given Defendant…
…NON-PARTY MS. RANSOME HAS PRODUCED DOCUMENTS RELEVANT TO JANE DOE 43. ...................................................................................................................22 CONCLUSION............................................................................................................................. 23 CERTIFICATE…
…innocence. You have to stand up and deny the allegations or be branded guilty by association and that may lead to other investigations and worse. I feel I am going around in circles. I know what is right to do…
…NON-PARTY MS. RANSOME HAS PRODUCED DOCUMENTS RELEVANT TO JANE DOE 43. ...................................................................................................................22 CONCLUSION............................................................................................................................. 23 CERTIFICATE…
…APPEAR AND RESPOND . 10 IV. MS. RANSOME MUST BE REQUIRED TO PRODUCE REPONSIVE DOCUMENTS THAT HAVE BEEN WITHELD WITHOUT BASIS, AND IDENTIFY ANY OTHER DOCUMENTS WITHELD ................................................................................................... 12 CONCLUSION .............................................…
…BURDEN .......................................................... 17 CONCLUSION ............................................................................................................................. 20 i Case 1:15-cv-07433-LAP Document 218 Filed 06/15/16 …
…10 IV. MS. RANSOME MUST BE REQUIRED TO PRODUCE REPONSIVE DOCUMENTS THAT HAVE BEEN WITHELD WITHOUT BASIS, AND IDENTIFY ANY OTHER DOCUMENTS WITHELD ................................................................................................... 12 CONCLUSION ..................................................................…
…R. Evid. 801(d)(2) ................................................................................................................... 9 Other Authorities The Conjurer’s Circle – The Fifth Amendment in Civil Cases, 91 Yale LJ. 1062 (1982) ................................................................................…
…See Dkts. 849, 851, 903. The motions therefore “can fairly be assumed to [have played] a role in [Judge Sweet’s] deliberations” as to other rulings, see Lugosch, 435 F.3d at 123, such as rulings on later motions and…
…all emails—whether saved or deleted – and irrespective of which account they came from; not a single responsive email was located - from any Mindspring account and no emails were located from Earthlink or any other secret, hidden, “undisclosed” email account…
…be transferred by way of this e-mail. Use of this or any other e-mail facility signifies consent to any interception we might lawfully carry out to prevent abuse of these facilities . Associated Newspapers ltd. Registered Office: Northcliffe House…
…Counsel is not permitted to intentionally harass or embarrass a non-party witness during a deposition. See Smartix 5 International LLC v. Garrubbo, Romankow & Capese, No. 06 CIV 1501 (JGK), 2007 WL 41666035 at *2( Court protecting deponent from annoyance…
…3377. As set forth in her earlier filings, Giuffre supports the unsealing of this case’s docket. See Dkt. 995 at 7 (“[A]ll of the documents in question are judicial documents, and accordingly the entire record should be unsealed…
…custodian, location and general description of relevant documents, including pertinent insurance agreements, and other physical evidence, or information of a similar nature.” Local Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil…
…Philip Barden; Ross Gow I am out of my depth to understanding defamation and other legal hazards and don't want to end up in a law suit aimed at me from anyone if I can help it. Apparently even…
…0022 http://www.bsfllp.com The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that, among other protections, is the subject of attorney-client privilege…
…New York, NY 10022, before a certified court reporter or other officer duly authorized to administer oaths. The deposition will be recorded by stenographic means. Pursuant to Rule 45, Defendant Ghislaine Maxwell also hereby provides Notice of Service of Subpoena…
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