…York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S MOTION TO COMPEL DATA FROM DEFENDANT’S UNDISCLOSED EMAIL ACCOUNT AND FOR AN ADVERSE INFERENCE INSTRUCTION Plaintiff, Virginia …
Case 1:15-cv-07433-LAP Document 1202-2 Filed 01/27/21 Page 1 of 10 Case 1:15-cv-07433-LAP Document 1202-2 Filed 01/27/21 Page 2 of 10 accounts.” II. APPLYING THE SEARCH…
…Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S REPLY IN SUPPORT OF MOTION TO COMPEL DATA FROM DEFENDANT’S UNDISCLOSED EMAIL ACCOUNT AND FOR AN ADVERSE INFE…
…following or if there is some other agreement you think we reached: 1. I will endeavor to have my client gain access to an earthlink account that you believe is hers. Your basis for that belief is a disk you…
…please use IMAP Capable software (or a functional equivalent) to capture all of the sent/received emails from Ms. Maxwell's various email accounts, including but not limited to the following: (1) GMaxl @ellmax.com (and any other accounts at…
…and violate our rights as victims by giving Jeffrey Epstein a plea lxirgain and immunity to only take accreditation for one account of the sensi ti ve subject of procuring us undernge gi rls for the usage ofprostin1tion internationally to…
…please use IMAP Capable software (or a functional equivalent) to capture all of the sent/received emails from Ms. Maxwell's various email accounts, including but not limited to the following: (1) (and any and any other …
… 24 A Firth . 25 A Fifth. 25 Q Do you haven bank account at Chase Bnnk 16 ( Pa ge s 58 t o 61) U.S. Legal Suppor…
…her? 3 A. It's on a -- it's on my 4 computer. 5 Q. Okay. In your Yahoo 6 account? 7 A. Yes. 8 Q. Did you have any agreement 9 with her to have any additional 10 conversation…
…have valuable privacy interests at stake that overcome the “lesser” presumption of access. This argument is contrary to the Protocol and does not account for the many practical problems that persist, through no fault of the Court or the parties…
…470, 474 (S.D.N.Y. 1977) (“The failure of [a corporate officer] to account in any way for his nonproduction of corporate books, coupled with the reasonable belief that the officer was the custodian of such records, was prima…
…a respected medical professional and her husband a well-respected businessman. His account does not accord with any reports made to law enforcement (Mr. Rizzo himself did not make any reports to law enforcement regarding the events that he says…
…the mainstream media and every business, blogger and individual with a web access or a social media account. It is not possible to overstate the close relationship between the documents plaintiff wants to unseal in this case and the criminal…
…Defendant has called Ms. Giuffre’s entire account “untrue” and “obvious lies.” Defendant has instead tried to portray her role as nothing more than an Epstein employee performing typical household management duties. Any personal knowledge Defendant has of Epstein’s…
…Defendant has called Ms. Giuffre’s entire account “untrue” and “obvious lies.” Defendant has instead tried to portray her role as nothing more than an Epstein employee performing typical household management duties. Any personal knowledge Defendant has of Epstein’s…
…high school student as part of 15 this massage recruiting scheme. He testified that Maxwell was 16 on a bank account for the Palm Beach house at the time he was, 17 they were jointly able to write checks, etc.…
…Defendant has called Ms. Giuffre’s entire account “untrue” and “obvious lies.” Defendant has instead tried to portray her role as nothing more than an Epstein employee performing typical household management duties. Any personal knowledge Defendant has of Epstein’s…
…375 (S.D.N.Y. 2007) (rejecting opposition to unsealing on the basis that the celebrity status of Michael Jackson would make portions of the record “subject to sensational media accounts”). Second, as to the documents regarding information that is…
…375 (S.D.N.Y. 2007) (rejecting opposition to unsealing on the basis that the celebrity status of Michael Jackson would make portions of the record “subject to sensational media accounts”). Whether a protective order is in place does not…
…Fair article: “What do you have on the girls?” [Epstein] would ask the question over and over again. What I had “on the girls” were some remarkably brave first-person accounts. Three on- the-record stories from a family: a…
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