…in which she works – the U.S. Attorney’s Office for the Southern District of Florida – has been recused by the Justice Department “from prospective responsibility for any criminal investigation or potential prosecution relating to Jeffrey Epstein’s alleged sexual…
…for Adverse Inference Instruction); Docket Entry 338 (Supplement based in New Information). When Defendant refused to participate in electronic discovery, this Court ordered Defendant to collect and produce data based on mutually agreed upon search terms, (June 20, 2016 Order)…
…late production of important emails. These two issues developed as follows. Defendant’s Failure to Answer Certain Questions During her first deposition, Defendant improperly refused to answer certain questions. Accordingly, the Court ordered a second deposition, directing the Defendant to…
…Civ. P. 26(f)(3)(C). Defendant having admitted to deletion practices that indicate relevant documents and also refused to detail document search methods, good cause exists to warrant court supervised examination of her electronic devices. Accordingly, Plaintiff’s motion…
…her to Epstein’s mansions to be sexually abused. At several points during her recent deposition, Ms. Maxwell refused to answer Ms. Giuffre’s questions about Epstein, but instead told her she should go ask Epstein about the subject. See…
…s counsel, Philip Barden, is also counsel for Mr. Gow. Mr. Barden refused to accept service of process of Ms. Giuffre’s Rule 45 subpoena on Mr. Gow’s behalf, despite extensive correspondence with Ms. Giuffre’s counsel, and her…
…used during the relevant period were excluded from this “search.” Moreover, Defendant has inappropriately refused to disclose what email accounts she has used during the relevant period for which this Court ordered her to produce documents. In the briefing, Ms…
…her to Epstein’s mansions to be sexually abused. At several points during her recent deposition, Ms. Maxwell refused to answer Ms. Giuffre’s questions about Epstein, but instead told her she should go ask Epstein about the subject. See…
…unavailing. First, Ms. Giuffre is entitled to question the Defendant on Defendant’s press agent who she refused to produce for a deposition, despite him being her agent and despite their sharing the same attorney, forcing Ms. Giuffre to litigate…
…Civ. P. 26(f)(3)(C). Defendant having admitted to deletion practices that indicate relevant documents and also refused to detail document search methods, good cause exists to warrant court supervised examination of her electronic devices. Accordingly, Plaintiff’s motion…
…168, 222 (S.D.N.Y. 2013) (granting an adverse inference when defendants refused to produce documents pursuant to the District Court’s order). Where “an adverse inference ... is sought on the basis that the evidence was not produced in…
…168, 222 (S.D.N.Y. 2013) (granting an adverse inference when defendants refused to produce documents pursuant to the District Court’s order). Where “an adverse inference ... is sought on the basis that the evidence was not produced in…
…for example) Ms. Giuffre’s Request No. 12, which sought Defendant’s documents relating to Ms. Giuffre. That request was refused in writing on Friday, July 29, 2016, at 7:02 p.m. (EST). See McCawley Decl. at Exhibit 1…
…390 (2d Cir. 1981) (affirming dismissal pursuant to Rule 37 where plaintiff refused to produce certain records in violation of court discovery order and where false testimony, material misrepresentations by counsel and foot-dragging were used in an effort to…
…168, 222 (S.D.N.Y. 2013) (granting an adverse inference when defendants refused to produce documents pursuant to the District Court’s order). Where “an adverse inference ... is sought on the basis that the evidence was not produced in…
…for example) Ms. Giuffre’s Request No. 12, which sought Defendant’s documents relating to Ms. Giuffre. That request was refused in writing on Friday, July 29, 2016, at 7:02 p.m. (EST). See McCawley Decl. at Exhibit 1…
…the Court’s Order and Direct Defendant to Answer Deposition Questions (DE 314/356), Defendant was again evasive and refused to answer questions during her second deposition, despite the court’s specific direction that she sit for 1 Maxwell Depo…
…cost. II. AN ADVERSE INFRERENCE INSTRUCTION IS WARRANTED In this litigation as the Court will recall, Defendant first refused to produce any documents at all - Ms. Giuffre had to litigate for Defendant to commence discovery (DE 28). Defendant then refused…
…As to both, Ms. Maxwell provided releases for Plaintiff’s signature. On March 16, 2016, Plaintiff refused to provide the names of any of Plaintiff’s treating physicians, nor the requested releases, claiming “privilege.” Menninger Decl., Ex. A. On March…
…for example) Ms. Giuffre’s Request No. 12, which sought Defendant’s documents relating to Ms. Giuffre. That request was refused in writing on Friday, July 29, 2016, at 7:02 p.m. (EST). See McCawley Decl. at Exhibit 1…