gov.uscourts.nysd.447706.223.2.pdf PDF
…Page 3 of 7 On Apr 6, 2016, at 11:46 AM, Sigrid McCawley wrote: That works fine - thank you. Sigrid S. McCawley Partner BOIES, SCHILLER & FLEXNER LLP 401 East Las Olas Blvd., Suite 1200 Fort Lauderdale…
…Page 3 of 7 On Apr 6, 2016, at 11:46 AM, Sigrid McCawley wrote: That works fine - thank you. Sigrid S. McCawley Partner BOIES, SCHILLER & FLEXNER LLP 401 East Las Olas Blvd., Suite 1200 Fort Lauderdale…
…Yeah, that's just random paper. 4 Q So you had a green spiral notebook that 5 you began sometime in 2011 or 2012 in which you wrote 6 down your recollections about what had happened to 7 you, and…
…Yeah, that's just random paper. 4 Q So you had a green spiral notebook that 5 you began sometime in 2011 or 2012 in which you wrote 6 down your recollections about what had happened to 7 you, and…
…I think it was 10 have read what he wrote down to determine whether 11 last week or the last ten days anyway -- I could 11 or not he took down that which you had said or 12 tell you…
…company. Plaintiff’s counsel, Meredith Shultz, wrote on May 17, 2016, regarding an account of Plaintiff’s (that she claims she cannot access but for which relevant and responsive emails were located on her computer): - “Regarding her live.com address…
…this. 15 A. Okay. We've been together 16 almost a year. 17 Q. And what is your current 18 occupation? 19 A. I'm a writer. 20 Q. And what do you write? 21 A. Just stuff, you know? …
…this. 15 A. Okay. We've been together 16 almost a year. 17 Q. And what is your current 18 occupation? 19 A. I'm a writer. 20 Q. And what do you write? 21 A. Just stuff, you know? …
…burned, right? 17 A. Yes. 18 Q. And you wrote that journal in order to 19 collect your thoughts? 20 A. To get everything out of here and on to 21 paper. 22 Q. Have you made any other notes…
…~ a y s that he did not see anyone molest or sexually v i o l a ~ m . wrote out a statement, it is included in this record. It should be noted that I was unable to record …
…Ms. Ransome at her deposition, she possesses other responsive communications. For example, she testified that she wrote to the NY Post reporter, Maureen Callahan, in an attempt to sell her story to the media, in or about October 2016. Pottinger…
…Ms. Ransome at her deposition, she possesses other responsive communications. For example, she testified that she wrote to the NY Post reporter, Maureen Callahan, in an attempt to sell her story to the media, in or about October 2016. Pottinger…
…confer, (2) stated that any discussion of their collection procedures inappropriate, and (3) wrote that “[w]e do not believe we have an obligation to describe for your [sic] our document search methods.” See McCawley Decl. at Exhibit 1, April…
…See id., Ex. G. On March 8, defense counsel again wrote and detailed additional deficiencies in the initial disclosures, in particular, her client’s statements to law enforcement, her client’s prior deposition testimony, and the many documents that Plaintiff…
…private journal, and I 10 didn't want it anymore. So we burned it. 11 Q (BY MS. MENNINGER) When did you write 12 that journal? 13 A Just over time. I started writing it 14 probably in, I don…
…private journal, and I 10 didn't want it anymore. So we burned it. 11 Q (BY MS. MENNINGER) When did you write 12 that journal? 13 A Just over time. I started writing it 14 probably in, I don…
…private journal, and I 10 didn't want it anymore. So we burned it. 11 Q (BY MS. MENNINGER) When did you write 12 that journal? 13 A Just over time. I started writing it 14 probably in, I don…
…this. 15 A. Okay. We've been together 16 almost a year. 17 Q. And what is your current 18 occupation? 19 A. I'm a writer. 20 Q. And what do you write? 21 A. Just stuff, you know? …
…as a positive command : "This is the sta t ement ." Maxwell also cites Davis v. Costa-Gavras, involving a libel claim against an autho r who wrote a book about a mi lita ry coup in Chile . 580 F . Supp…
…private journal, and I 10 didn't want it anymore. So we burned it. 11 Q (BY MS. MENNINGER) When did you write 12 that journal? 13 A Just over time. I started writing it 14 probably in, I don…
…that's uRJn the.d ouds now,, bonfire. I I A. Yes. Q. And you wrote that journal in order to collect your thoughts? I A. To get everything out of here and on to a er. I Menninger Deel.…