…Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ____________________________/ DECLARATION OF MEREDITH SCHULTZ IN SUPPORT OF PLAINTIFF VIRGINIA GIUFFRE’S MOTION FOR FINDING OF CIVIL CONTEMPT AGAINST NADIA MARCINKOVA FOR IGNORING SUBPOENA AND FOR ASSOCIATED SANCTIONS…
…undersigned counsel, hereby files this motion for a protective order, barring enforcement of a defense subpoena submitted to Apple, Inc. for all of the records associated with her “iCloud” email account. Counsel for Ms. Giuffre has already reviewed Ms. Giuffre…
…undersigned counsel, hereby files this motion for a protective order, barring enforcement of a defense subpoena submitted to Microsoft Corporation for all of the records associated with Ms. Giuffre’s live.com email account and Hotmail.com account. Defendant is…
…C ou rt’s A pril21,2016,ru lingM s.Giu ffre has mad e significantefforts to try to trackd own and collectany med icalrecord she can find from 1999 to the present,inclu d ingpayingall fees associated withthatcollection process…
…surnames is too broad a request or overly burdensome, particularly, as you have not presented any numbers of documents associated with those names, since you have not yet run the terms. Should one of the names somehow yield thousands of…
…other accounts at mindspring.com); (3) any of Ms. Maxwell's email account associated with The Terramar Project (including any account ending [email protected]); and (4) any other email accounts either used in the past, or currently in use. …
…401 E. Las Olas at Gray Robinson's office - suite 1000. Michael Austrich -Thursday June 23 rd 9:00 a.m. - Ocala Florida - Owens & Associates - 108 N. Magnolia Ave Tony Figueroa - Friday June 24 t h - 9:00 a.m. …
…delete it from your system. Please be advised that the views and opinions expressed in this e-mail may not reflect the views and opinions of Associated Newspapers Limited or any of its subsidiary companies . We make every effort to…
…Edwards; Paul Cassell ([email protected]) Subject: Conferral regarding forensic search Meredith – Apart from (i) the list of witness names you believe might be associated with the term “massage” (“massage” and related terms that you requested have been searched)…
…not limited to the following: (1) (and any and any other accounts at (3) any of Ms. Maxwell's email account associated with The Terramar Project (including any accoun …
…Edwards; Paul Cassell ([email protected]) Subject: Conferral regarding forensic search Meredith – Apart from (i) the list of witness names you believe might be associated with the term “massage” (“massage” and related terms that you requested have been searched)…
…s),” “You,” and “Your,” the definitions of “Relevant Period” and “relevant time frame,” the phrases “relating to” and “associated with,” the seeking of documents and information already in the possession of counsel for plaintiff or readily obtainable from other sources…
…of all persons involved in the Communication, including the identity of the law enforcement agency with whom the agent is or was affiliated; d. the case number associated with any such Communication; e. the subject matter of any such Communication; …
…01/05/24 Page 16 of 17 Adverse Inference Instruction, and 2) for attorneys’ fees and costs associated with responding to this Motion pursuant to 37(a)(5)(B), and such other and further relief as this Court deems just. …
…a past or present officer, director, agent or servant, including any attorney (associate or partner) or paralegal. 6. "Including'' means including ·without limitations. 7. "Jeffrey Epstein" includes Jeffrey Epstein and any entities owned or controlled by Jeffrey Epstein, any employee…
… 10 scandal, was it that they are associated or 10 MR. CRITTON: Form . 11 friends with Jeffrey Epstein or is it that you 11 THE WITNESS: She knew what was going on. 12 have information and you have this confidentiality…
…Filed 01/05/24 Page 9 of 11 Other Email Accounts In addition to her home and work email addresses, Plaintiff also requested that Ms. Maxwell access two other email accounts that Plaintiff believes are associated with Ms. Maxwell, specifically …
…of all persons involved in the Communication, including the identity of the law enforcement agency with whom the agent is or was affiliated; d. the case number associated with any such Communication; e. the subject matter of any such Communication; …
…is or was affiliated; 9 Case 1:15-cv-07433-RWS Document 71-2 Filed 03/23/16 Page 11 of 45 d. the case number associated with any such Communication; e. the subject matter of any such Communication…
… loss of enjoyment of life; invasion of privacy; and other damages associated with Defendants' actions. Plaintiff will incur medical and psychological expenses. These injuries are permanent in nature and Plaintiff will continue to suffer from them in the future.” See…
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