giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…Defendant has not disclosed,
nor produced data from, the email account she used while abusing Ms. Giuffre from 2000-2002
in violation of this Court’s Order [DE 352]. Ms. Giuffre hereby moves to compel Defendant to
produce this data…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.33
12 pg
…Defendant has not disclosed,
nor produced data from, the email account she used while abusing Ms. Giuffre from 2000-2002
in violation of this Court’s Order [DE 352]. Ms. Giuffre hereby moves to compel Defendant to
produce this data…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.5
2 pg
…would appreciate it i f - would come out and say she was your g'friend - I think she was from end 99 to
2002
THE TERRAMAR PROJECT
FACEBOOK
TWITTER
G+
PINTEREST
INST AGRAM
PLEDGE
THE DAILY CATCH
please note
The…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 pg
…Defendant has not disclosed,
nor produced data from, the email account she used while abusing Ms. Giuffre from 2000-2002
in violation of this Court’s Order [DE 352]. Ms. Giuffre hereby moves to compel Defendant to
produce this data…
giuffre-maxwell
gov.uscourts.nysd.447706.18.0
5 pg
…Int’l
Ltd., 206 F.R.D. 367, 368 (S.D.N.Y 2002). Good cause may be shown where a party (1) has
filed a dispositive motion; (2) the stay is for a short period of time; and (3…
giuffre-maxwell
gov.uscourts.nysd.447706.468.0
12 pg
…Defendant has not disclosed,
nor produced data from, the email account she used while abusing Ms. Giuffre from 2000-2002
in violation of this Court’s Order [DE 352]. Ms. Giuffre hereby moves to compel Defendant to
produce this data…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.28_4
5 pg
…corn> wrote:
I would appreciate it if shelley would come out and say she was your gTriend - I think she was from end 99 to
2002
THE TERRAMAR PROJECT
FACEBOOK
TWITTER
G+
PINTEREST
INSTAGRAM
PLEDGE
THE DAILY CATCH
please note…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.1
8 pg
…is ordered to collect all ESI by imaging her computers and collecting all email and
text messages on any devices in Defendant’s possession or to which she has access that
Defendant used between the period of 2002 to present…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…53184 .............................................................................. 22
Medical Components, Inc. v. Classic Medical, Inc.,
210 F.R.D. 175 (M.D.N.C. 2002) ............................................................................................. 21
Night Hawk Limited v. Briarpatch Limited,
No. 03 CIV. 1382 (RWS)…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.9
29 pg
…53184 .............................................................................. 22
Medical Components, Inc. v. Classic Medical, Inc.,
210 F.R.D. 175 (M.D.N.C. 2002) ............................................................................................. 21
Night Hawk Limited v. Briarpatch Limited,
No. 03 CIV. 1382 (RWS)…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.16
6 pg
…at #16-21 and 75-77. To the extent those initials
represent people from whom you have requested all communications (and which the Court has limited
to 1999-2002 and post-2002 as they relate to sex trafficking), for example…
giuffre-maxwell
gov.uscourts.nysd.447706.659.0
7 pg
…and in particular, the email accounts Defendant used
while she was abusing Ms. Giuffre from 2000-2002.1 Ms. Giuffre argued that in light of
Defendant’s unabashed and unabated pattern of recalcitrance regarding her discovery
obligations, and her clear…
giuffre-maxwell
gov.uscourts.nysd.447706.320.0
11 pg
…email and text messages on any devices in Defendant's possession or to which
she has access that Defendant used between the period of 2002 to present.
Defendant is further directed to run mutually- agreed upon search terms related
to…
giuffre-maxwell
gov.uscourts.nysd.447706.689.0
42 pg
…Distributors, Inc.,
106 F. Supp. 2d 462 (S.D.N.Y. 2000)....................................................................................... 10
Legg v. Chopra,
286 F.3d 286 (6th Cir. 2002) .................................................................................................... 11
LiButti v. United States,
107 F.3…
giuffre-maxwell
gov.uscourts.nysd.447706.279.0
8 pg
…is ordered to collect all ESI by imaging her computers and collecting all email and
text messages on any devices in Defendant’s possession or to which she has access that
Defendant used between the period of 2002 to present…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.17
6 pg
…at #16-21 and 75-77. To the extent those initials
represent people from whom you have requested all communications (and which the Court has limited
to 1999-2002 and post-2002 as they relate to sex trafficking), for example…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…recalls
one facility named “Growing Together” that was located in or around
Palm Beach, but she does not recall the dates when she resided at the
facility.
! From 2000-2002, Ms. Giuffre lived and travelled with Jeffrey
Epstein and stayed…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…there is no indication or
inference that either of these accounts were created or used in the 2000 to 2002 time frame as Plaintiff claims.
3
Case 1:15-cv-07433-LAP Document 1330-16 Filed 01/05/24…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…DeGeorge Financial Corp., 306 F.3d 99, 108 (2d Cir. 2002)).
Furthermore, as discussed in detail in Ms. Giuffre’s Motion for an Adverse Inference
Instruction (DE 315), an adverse inference is appropriate regarding the documents that
Defendant is withholding…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.22
22 pg
…would appreciate it i f - would come out and say she was your g'friend - I think she was from end 99 to
2002
THE TERRAMAR PROJECT
FACEBOOK
TWITTER
G+
PINTEREST
INST AGRAM
PLEDGE
THE DAILY CATCH
please note
The…
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