…Account Ms. Giuffre has knowledge of the account because it was listed as part of Defendant’s contact information (including phone number) on documents gathered by the police from Epstein’s home, and turned over to the Palm Beach County…
…of reference, Plaintiff’s specific position as to each document at issue is also included in the chart attached to this brief as Exhibit A. 2 The Brown minimal redactions encompass: (1) “personally identifying information such as personal phone numbers…
…For example, in a letter sent on June 8, 2016, and in a meet and confer call on July 26, 2016, counsel for Ms. Giuffre asked Defendant to run Ms. Giuffre’s name as a search term to find documents…
…For example, in a letter sent on June 8, 2016, and in a meet and confer call on July 26, 2016, counsel for Ms. Giuffre asked Defendant to run Ms. Giuffre’s name as a search term to find documents…
…For example, in a letter sent on June 8, 2016, and in a meet and confer call on July 26, 2016, counsel for Ms. Giuffre asked Defendant to run Ms. Giuffre’s name as a search term to find documents…
…opposition to Defendant’s motion for summary judgment (ECF No. 586 to 586-3, inclusive); (c) All currently sealed documents in support of Defendant’s Reply in support of motion for summary judgment (ECF No. 620 to 621, inclusive)…
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