giuffre-maxwell
gov.uscourts.nysd.447706.965.0
9 pg
…s,
14 and was dismissed shortly thereafter. Two times since May we
15 have asked for agreed upon protocol with the plaintiff's
16 counsel to finish up destroying or exchanging-back confidential
17 documents. The first request was shortly…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.4
21 pg
…Instead, Defendant’s brief quotes extensively from cases
in which parties destroyed evidence after the cause of action accrued and after the parties had
notice of a duty to preserve. Those are inapposite.
Because this is a losing argument for…
giuffre-maxwell
gov.uscourts.nysd.447706.57.2
30 pg
…WLR 114. That case is said to demonstrate
that it is possible to disclose advice to an outsider without destroying or waiving the
privilege which attaches to it other than as between the privilege owner and the third
party. Those…
giuffre-maxwell
gov.uscourts.nysd.447706.279.0
8 pg
…2009) (“Where a
party violates a court order—either by destroying evidence when directed to preserve it or by
failing to produce information because relevant data has been destroyed—Rule 37(b) of the
Federal Rules of Civil Procedure provides…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…however am not intimated and
need your help. These men distroyed my life.
I apologize for my heated first email to you however when I came
across your acticle in the NYC Post, how that happened I don't
know…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.7
14 pg
…However, your
13 own experts, cocounsel and staff may have
limited internal use of same with the
14 understanding that we agree to destroy your
realtime rough draft and/or any computerized
15 form, if any, and replace it with…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.28_4
5 pg
…com, and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
PRIVILEGED GM 001087
CONFIDENTIAL
Case 1:15-cv-07433-LAP Doc…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.5
2 pg
…error, please notify us immediately by
return e-mail or by e-mail to [email protected], and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
1
…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.14
3 pg
…have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to [email protected], and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.2
3 pg
…have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to [email protected], and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
…
giuffre-maxwell
1320-14
3 pg
…have received this
communication in error, please notify us immediately by
return e-mail or by e-mail to [email protected], and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
…
giuffre-maxwell
gov.uscourts.nysd.447706.967.0
7 pg
…proh i bited from disclosing such materials to
non - parties except on certain conditions , and (b) required at
the conclusion of the case to return or destroy each document
and all copies of these Confidentia l Ma t erials. Id …
giuffre-maxwell
gov.uscourts.nysd.447706.1206.13
22 pg
…conclusively establishing the privacy
of Maxwell’s deposition testimony. Indeed, under the plain terms of the Protective Order,
were required to return or destroy all confidential information at the
conclusion of the case, including Maxwell’s deposition transcripts. refused to…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.2
23 pg
…upon, each
document and all copies thereof which have been designated as CONFIDENTIAL
shall be returned to the party that designated it CONFIDENTIAL, or the parties
may elect to destroy CONFIDENTIAL documents. Where the parties agree to
destroy CONFIDENTIAL documents…
giuffre-maxwell
gov.uscourts.nysd.447706.1100.1
13 pg
…has been made part of
the record of this case, Defense Counsel shall return to the
Government or securely destroy or delete all Discovery,
including but not limited to Confidential Information, within 30
days of the expiration of the period…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…questions were asked
after this answer.
F. Objected to Question Number 7
“In 2005, were you aware of any effort to destroy records of messages you had taken of
women who had called Mr. Epstein in the prior period?”
Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.28
24 pg
…it. After being
notified, a party must promptly return, sequester, or destroy the specified
(3) Quashing or Modifying a Subpoena. infonnation and any copies it has; must not use or disclose the information
(…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…at pg. 184:14-185:6.
Q. “In 2005, were you aware of any effort to destroy records of messages you had taken
of women who had called Mr. Epstein in the prior period?
MR. PAGLIUCA: Don’t answer that…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.22
22 pg
…please notify us immediately by
return e-mail or by e-mail to [email protected], and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
PRIVILEGED GM_001062
…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…at pg. 184:14-185:6.
Q. “In 2005, were you aware of any effort to destroy records of messages you had taken
of women who had called Mr. Epstein in the prior period?
MR. PAGLIUCA: Don’t answer that…
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