…INTRODUCTION .......................................................................................................................... 1 I. MS. RANSOME UNJUSTIFIABLY FAILED TO PRODUCE A PRIVILEGE LOG, RESULTING IN A WAIVER OF HER PRIVILEGE ............................................................ 1 II. MS. RANSOME REFU…
…INTRODUCTION .......................................................................................................................... 1 I. MS. RANSOME UNJUSTIFIABLY FAILED TO PRODUCE A PRIVILEGE LOG, RESULTING IN A WAIVER OF HER PRIVILEGE ............................................................ 1 II. MS. RANSOME REFU…
…Check one: By handing it to a person identified to me as the Witness or by leaving it with the Witness who refused service. I attempted to serve the Witness on _______ occasions but have not been able to…
…in this case, (b) the fact the information can be obtained from other sources, 1 Plaintiff flatly mis-represents to the Court that Ms. Maxwell “refused” to answer the questions posed to her, as the actual transcript amply demonstrates. Ms…
…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…
…in this case, (b) the fact the information can be obtained from other sources, 1 Plaintiff flatly mis-represents to the Court that Ms. Maxwell “refused” to answer the questions posed to her, as the actual transcript amply demonstrates. Ms…
…in this case, (b) the fact the information can be obtained from other sources, 1 Plaintiff flatly mis-represents to the Court that Ms. Maxwell “refused” to answer the questions posed to her, as the actual transcript amply demonstrates. Ms…
…in this case, (b) the fact the information can be obtained from other sources, 1 Plaintiff flatly mis-represents to the Court that Ms. Maxwell “refused” to answer the questions posed to her, as the actual transcript amply demonstrates. Ms…
…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…
…Plaintiff moved to quash the subpoena to obtain the information contained in the account and has refused to sign the release provided to her that would allow the production of that information under the terms of a subpoena issued to…
…RESIDENCE, ONCE AGAIN THE WHITE MALE HAD FORCED SEXUAL INTERCOURSE WITH HER. STATED THAT SHE WAS NOT INJURED AS A RESULT. WHEN/ASKED ONCE AGAIN TO PROVIDE INFORMATION ON THE IDENTITY OR THE DESCRIPTION/OF THE SUSPECTS, SHE REFUSED. SGT…
…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…
…Civ . P. 26(f) (3) (C). Defendant having admitted to de l etion 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…
…Strike for Failure to Confer, inexplicably and inaccurately claiming 1) that defendant is running “secret search terms” and 2) claiming that defendant’s counsel refused to confer despite the clear conferral letter and request for telephone conference. See July 18…
…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…
…Ms. Giuffre has made this collection in compliance with a standard ESI Protocol that was provided to Defendant, but that Defendant has refused to comply with. Courts have found this to be the best practice to ensure compliance with Fed…
…that statement and decided to approach 23 the reporter to try to sell her story. She did that just a 24 couple weeks before she called plaintiff's counsel. That 25 New York Post reporter refused, apparently, to publish her …