…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…
…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…
…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…
…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…
…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…
…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…
…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…
…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…
…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…
…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…
…the island. Some photos, in fact, capture her image on what appears to Little St. James Island. Indeed, she inserted photographs in her Response and suggested that such photographs of Ms. Maxwell had been taken by her. See Opp’n…
…the island. Some photos, in fact, capture her image on what appears to Little St. James Island. Indeed, she inserted photographs in her Response and suggested that such photographs of Ms. Maxwell had been taken by her. See Opp’n…
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