giuffre-maxwell
gov.uscourts.nysd.447706.1327.14
4 pg
…ruled maintains an attorney-client relationship with our client (and to the extent
others are copied on his emails, those would be captured by searches for the other people’s names). You included my
client’s boyfriend of many years…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…demands. The result of the application of these search terms is
proof that she has been compliant with her discovery obligations all along. No new non-
privileged documents were captured through utilization of the process demanded by Plaintiff. As
Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…Plaintiff has produced some email communications with Churcher, although in light of Plaintiff’s statements
concerning the regular deletion of emails, there are likely email communications that were not captured by Plaintiff
in Ms. Churcher’s possession or control. Nevertheless…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…demands. The result of the application of these search terms is
proof that she has been compliant with her discovery obligations all along. No new non-
privileged documents were captured through utilization of the process demanded by Plaintiff. As
Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.15
5 pg
…ruled maintains an attorney-client relationship with our client (and to the extent
others are copied on his emails, those would be captured by searches for the other people’s names). You included my
client’s boyfriend of many years…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
… Accordingly, we have
23 captured and produced every electronic document to which we
24 have access.
25 And I'd like to speak a minute about the legality of
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.2_1
10 pg
…a
reasonable, good-faith syntax to capture communications with those individuals -- for example:
“Alex* w/50 Hall.” Sometimes that takes some trial-and-error – I’m happy to be of any
assistance with regard to that process. Please let me…
giuffre-maxwell
gov.uscourts.nysd.447706.96.0
15 pg
…case, and Defendant should not be allowed to refuse to produce critically
relevant information.
7
Case 1:15-cv-07433-LAP Document 96 Filed 04/13/16 Page 11 of 15
Giuffre’s counsel captured all of Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.16
6 pg
…ruled maintains an attorney-client relationship with our client (and to the extent
others are copied on his emails, those would be captured by searches for the other people’s names). You included my
client’s boyfriend of many years…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.0_2
65 pg
…a
reasonable, good-faith syntax to capture communications with those individuals -- for example:
“Alex* w/50 Hall.” Sometimes that takes some trial-and-error – I’m happy to be of any
assistance with regard to that process. Please let me…
giuffre-maxwell
gov.uscourts.nysd.447706.589.0
24 pg
…including Wikipedia.com, captured various tweets issued by
Cernovich.6 Cernovich’s tweets show that his interest in sexual assault is not simply journalistic,
as he claims, but instead betrays a purient interest to fetishize rape:
Another tweet he issued…
giuffre-maxwell
gov.uscourts.nysd.447706.207.0
7 pg
…indeed, emails from these accounts have been
produced as some were embedded in the data in Ms. Giuffre’s accessible email account that were
captured and searched by Ms. Giuffre’s counsel), the subpoena is duplicative and should not be…
giuffre-maxwell
gov.uscourts.nysd.447706.1046.0
3 pg
…172,
199, 230. But Maxwell’s approach would capture far fewer docket entries implicating Does 1 and
2, and is therefore inconsistent with the Court’s decision to proceed by non-party, as opposed to
by motion.1 It would…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…2016, this Court Granted in Part Ms. Giuffre’s Motion for Forensic Exam,
and directed Defendant to capture her data and run mutually agreed-upon search terms. The
Court also ordered Defendant to produce documents to Ms. Giuffre by July…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.2
13 pg
…production
from Defendant's electronic media. Accordingly, 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…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…2016, this Court Granted in Part Ms. Giuffre’s Motion for Forensic Exam,
and directed Defendant to capture her data and run mutually agreed-upon search terms. The
Court also ordered Defendant to produce documents to Ms. Giuffre by July…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.43
12 pg
…August 9, 2016, DE 352 at p. 1-2, Order directing Defendant to “capture all of the
sent/received emails from Defendant’s multiple email accounts, including . . . any other email
accounts Defendant has used in the past or currently uses…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.19
21 pg
…2016, this Court Granted in Part Ms. Giuffre’s Motion for Forensic Exam,
and directed Defendant to capture her data and run mutually agreed-upon search terms. The
•
Court also ordered Defendant to produce documents to Ms. Giuffre by July…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.13
13 pg
…and production
from Defendant's electronic media. Accordingly, 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) …
giuffre-maxwell
gov.uscourts.nysd.447706.1327.17
6 pg
…please use a reasonable, good-faith syntax to capture communications with
those individuals -- Sometimes that takes some trial-and-error – I’m happy to
be of any assistance with regard to that process. Please let me know what your syntax…
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