…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…
…A. Jeffrey Epstein and Ronald Rizzo Are Not Unavailable Plaintiff cannot claim that Jeffery Epstein and Ronald Rizzo are “unavailable witnesses” whose testimony can be presented by deposition at trial under Rule 34 of the Federal Rules of Civil Procedure…
…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…
…Honor rescheduled the Conference for July 25, 2019 at 3:00 p.m. I am unavailable on July 25 due to travel and will likely not even have telephone access at that time. Rather than further delay the process toward…
…on Ms. Maxwell’s counsel,” id. at 2, who has represented that her firm is unavailable to complete briefing until Defendant’s criminal trial is over. Under that case’s current schedule, trial will conclude sometime in January. At meet…
…of her long-time boyfriend and joint defense partner, Jeffrey Epstein. A blanket statement of “unavailability” is incredible – particularly without any description of the steps she has taken to make the emails available. Without taking any efforts to recover her …
…A party may establish relevance by “‘adduc[ing] sufficient evidence from which a reasonable trier of fact could infer that ‘the destroyed [or unavailable] evidence would have been of the nature alleged by the party affected by its destruction.’” Id…
…my view, is governed by Rule 32 of the Rules of Civil 9 Procedure. And those rules are clear with regard to 10 depositions as to unavailability of witness. And then we talk 11 about the requirements that, whether they…
…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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