…the Southern District of Florida (the “Office”), the Office was recused by the Department of Justice from prospective responsibility for any criminal investigation or potential prosecution relating to Jeffrey Epstein’s alleged sexual activities with minor females. As a result…
…example, a “public interest privilege” which is unavailable to individual, non-governmental litigants) and mundane (Plaintiff completely refused to answer interrogatories, even though they comply with the Federal and Local Rules). Because of the breadth of the issues raised, Defendant…
…264-1). Yet, during her second deposition, Defendant again refused to answer numerous questions regarding sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the Court should direct her to fully answer the relevant questions…
…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…
…ARE HIGHLY RELEVANT TO MS. RANSOME’S TESTIMONY IN THIS ACTION ................................................................................................................... 5 III. MS. RANSOME UNJUSTIFIABLY REFUSED TO ANSWER RELEVANT DEPOSTION QUESTIONS, AND SHE MUST BE COMPELLED TO RE-APPEAR AND RESPOND . 10 IV. MS. RA…
…directed Maxwell to sit for her deposition on April 22, 2016. During her deposition Defendant refused to answer the majority of the questions asked or stated that she had no memory of any of the events. As a result, Ms…
…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…
…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…
…Than Personal Service, and [DE 161] Declaration of Sigrid McCawley in Support of Plaintiff’s Motion for Leave to Serve Three Deposition Subpoenas By Means Other Than Personal Service.) Mr. Epstein refused to accept service, thereby forcing Ms. Giuffre to…
…ARE HIGHLY RELEVANT TO MS. RANSOME’S TESTIMONY IN THIS ACTION ................................................................................................................... 5 III. MS. RANSOME UNJUSTIFIABLY REFUSED TO ANSWER RELEVANT DEPOSTION QUESTIONS, AND SHE MUST BE COMPELLED TO RE-APPEAR AND RESPOND . 10 IV. MS. RA…
…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…
…As well, she was instructed by counsel not to answer questions about false statements published in the media attributed to her that were critically relevant and she refused to answer the questions. She later conceded no privilege precluded her answers…
…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…
…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…
…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…
…2019). 3 Doe 171 has to date refused to provide Plaintiff with all ex parte submissions or briefs she provided to the Court. 2 Case 1:15-cv-07433-LAP Document 1289 Filed 12/07/22 Page 3 of…
…She says she refused this > request.· Regarding further detail of the interview which I have reviewed I would like to add one further point to underscore the lack of probity in Ms Roberts claims At no point in Ms…