…Motion to Compel are at once novel (Plaintiff asserts, for 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…
…on remand. Setting aside issues of jurisdiction and prematurity, Ms. Maxwell’s counsel Jeffrey Pagliuca and I are unavailable to participate in-person in the conference (Laura Menninger is out of the country), although we could participate via telephone. Accordingly…
…a.m. EST. Case 1:15-cv-07433-LAP Document 87 Filed 04/07/16 Page 2 of 4 4. Counsel for Ms. Maxwell are both unavailable to appear in New York on April 13, 2016. 5. Mr. Pagliuca…
…time, so this had been sent to him 09:20:59 ·5· ·originally by Ms. Maxwell, and because he was 09:21:03 ·6· ·unavailable, she forwarded it to me for immediate action. 09:21:07 ·7· ·I therefore respond…
…effort to hide relevant information and prevent the fair examination of Plaintiff on her claims. Due to these multiple and repeated discovery violations, key information and documents were unavailable to Ms. Maxwell prior to Plaintiff’s depositions on May 3…
…684 N.Y.S.2d 443, 444 (1st Dep’t 1996) (“Notwithstanding [subpoenaing party’s] excuses offered to the contrary, no clear and specific showing has been made that the relevant material was unavailable elsewhere.”); Flynn, 235 15 Case…
…and some provid ers no longerex ist.A complete overview of what med icalrecord s are u navailable to M s.Giu ffre is below atA ppend ix A . Even if M s.Giu ffre had end less resou rces…
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