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.447706.1202.2_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.447706.1327.16
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.447706.207.0
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.447706.1200.11_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.447706.1327.19
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…
Comments