…this “new” witness. As it turns out, Plaintiff’s counsel Bradley Edwards, Paul Cassell and Stanley Pottinger had already signed a fee agreement to represent this witness more than two months earlier, on November 7, 2016. Plaintiff’s counsel still…
…deposition testimony, the majority of non-deposition documents herein were either produced by plaintiff or obtained with releases signed by plaintiff. Case 1:15-cv-07433-RWS Document 542 Filed 01/09/17 Page 2 of 7 3. Attached…
…a document 15 signed by Gerald 16 16 Lefcourt and 17 17 …
…this matter, it shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. See Protective Order [DE 62] signed on March 17, 2016…
…conferral in good faith.” The failure to show conferral in good faith necessarily means her counsel’s Rule 37(a)(1) certification was signed in violation of Rule 11(b). We do not mean to stand on some “technical” objection…
…this “new” witness. As it turns out, Plaintiff’s counsel Bradley Edwards, Paul Cassell and Stanley Pottinger had already signed a fee agreement to represent this witness more than two months earlier, on November 7, 2016. Plaintiff’s counsel still…
…other is by way of a stipulation. That is 15 what was done. There was a stipulation of dismissal signed by 16 both parties, that being the plaintiff and the defendants and 17 counsel, that has been done and that…
…14 258-6. Medical release information. Unseal but 15 redact medical information and addresses. 16 258-7. The signed medical releases. Unseal but 17 redact the tax returns and addresses. 18 258-8. Keep sealed. That's medical records. 19…
…are. a. There is no evidence that Doe 1 received or read the Notice from the Court, nor even that Doe 1 is still living. The return receipt was signed for by someone other than Doe 1. Ex. A. b…
…account numbers, and social security numbers). Request 22 (All Modeling Contracts Signed or Entered into By You): Non-party Ransome provided testimony that she did very little modeling while in New York because she was not successful at it, and…
…account numbers, and social security numbers). Request 22 (All Modeling Contracts Signed or Entered into By You): Non-party Ransome provided testimony that she did very little modeling while in New York because she was not successful at it, and…
…by You or on Your behalf during the years 200S - present. 21. All Docwnents reflecting any moneys received by You in exchange for any ..modeling" byYou. 22. All modeling contracts signed or entered into by You. 23. Any calendar, receipt…
…15 Florida, a document signed by Gerald 16 Lefcourt and Alan Dershowitz 17 Plaintiff's Exhibit Subpoena in this case 225 18 JEl0 for …
…records and, mere days before her deposition, Plaintiff signed releases for some of the institutions she attended in Florida. Defendant obtained records pursuant to those releases after the deposition (despite having sought them by discovery request in February). The transcripts…
…1, Barden Declaration, at 1 ¶ 3. But whatever the effect of this statement at the time Barden signed his declaration, it clearly had no effect when Defendant, through her attorneys in this case, chose to place the Declaration into evidence…
…as 15 indicated by me on the DEPOSITION f.RRata sheet hereof, 16 with the understanding that I offer these changes as if 17 still under oath. 18 19 Signed on the 1 day of …
…account numbers, and social security numbers). Request 22 (All Modeling Contracts Signed or Entered into By You): Non-party Ransome provided testimony that she did very little modeling while in New York because she was not successful at it, and…
…information has been disclosed. Indeed, Ms. Giuffre signed every medical records release that Defendant requested. There has been no deliberate “withholding” of information, much less withholding of information that would warrant the extreme sanction of precluding Ms. Giuffre from presenting…
…can presume, she believes her Interrogatory Responses of March 16, 2016, to be complete. They are not. The Responses are not signed by Plaintiff, nor are the Objections signed by Ms. McCawley. See Rule 33(b)(5); Menninger Decl. at…
…records and, mere days before her deposition, Plaintiff signed releases for some of the institutions she attended in Florida. Defendant obtained records pursuant to those releases after the deposition (despite having sought them by discovery request in February). The transcripts…
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