giuffre-maxwell
gov.uscourts.nysd.447706.1090.29_2
2 pg
…this
communication is strictly prohibited and no privilege is waived. If you have received this communication in error, please immediately
notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1]
giuffre-maxwell
gov.uscourts.nysd.447706.1328.33
3 pg
…part
is prohibited. If you have received the e-mail in error, please notify the sender and delete the e-mail and any
attachments from your computer system. Whilst any attachments may have been checked for viruses, you
should rely…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.27
3 pg
…part
is prohibited. If you have received the e-mail in error, please notify the sender and delete the e-mail and any
attachments from your computer system. Whilst any attachments may have been checked for viruses, you
should rely…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.9
6 pg
…part
is prohibited. If you have received the e-mail in error, please notify the sender and delete the e-mail and any
attachments from your computer system. Whilst any attachments may have been checked for viruses, you
should rely…
giuffre-maxwell
gov.uscourts.nysd.447706.96.0
15 pg
…this Motion for Clarification regarding this Court’s Ruling at the March 17, 2016
hearing1, and seeks a forensic examination of defendant’s computers and states as follows.
I. INTRODUCTION
Ms. Giuffre served Defendant with discovery requests on October 27…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.14
3 pg
…part
is prohibited. If you have received the e-ma.il in error. please notify the sender and delete the e-mail and any
attachments from your computer system. Whilst any attachments may have been checked for viruses, you
should…
giuffre-maxwell
gov.uscourts.nysd.447706.604.0
11 pg
…Imams,
priests, social media personalities, comedians, computer hackers, lawyers, college students,
musicians, and even so-called “online trolls.” Silenced was a look at what free speech meant in
1
Available at
giuffre-maxwell
gov.uscourts.nysd.447706.1326.2
3 pg
…part
is prohibited . If you have received the e-mail in error. please notify the sender and delete the e-mail and any
attachments from your computer system . Whilst any attachments may have been checked for viruses, you
should rely…
giuffre-maxwell
1320-14
3 pg
…part
is prohibited. If you have received the e-ma.il in error. please notify the sender and delete the e-mail and any
attachments from your computer system. Whilst any attachments may have been checked for viruses, you
should…
giuffre-maxwell
gov.uscourts.nysd.447706.541.0
10 pg
…PKC), 2016 WL 3583080, at *6 (S.D.N.Y.
June 28, 2016)................................................................................................................ 22
Enigma Software Grp. USA, LLC v. Bleeping Computer LLC, No. 16 CIV. 57 (PAE),
2016 WL 3773394, at *11 (S.D.N.Y. July 8, 2016) ....................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…to her own domain name) in one location but not another;
shortly afterward hackers breached the host computer.
It would be hard to overstate the “media’s” interest in this case. By “media” we
include all constituents of the twenty…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.43
12 pg
…judgment whether or not a document is responsive, not at the discretion of the party defendant to
look through her computer with absolutely no attorney supervision or any accountability for her
search process, especially one that is done completely in…
giuffre-maxwell
gov.uscourts.nysd.447706.1195.0_2
2 pg
…no matter how broad
its reach, provides no guarantee that compelled testimony will not somehow find its way into the
government’s hands for use in a subsequent criminal prosecution.” Andover Data Servs., a Div.
of Players Computer, Inc. v…
giuffre-maxwell
gov.uscourts.nysd.447706.49.0
12 pg
…Material. “Access to” is a very broad term. A burglar has “access to”
an unprotected house. A hacker has “access to” an unprotected computer. Simply because
someone has “access to” something does not confer the right to have it. And…
giuffre-maxwell
gov.uscourts.nysd.447706.936.0
21 pg
…entries related to motion for adverse
inference); ECF Nos. 125, 329 (entries related to motions concerning forensic examination of
computer); ECF No. 146 (entries related to brief in support of privilege claimed for Plaintiff's in
camera submission); ECF no…
giuffre-maxwell
gov.uscourts.nysd.447706.538.0
10 pg
…PKC), 2016 WL 3583080, at *6 (S.D.N.Y.
June 28, 2016)................................................................................................................ 22
Enigma Software Grp. USA, LLC v. Bleeping Computer LLC, No. 16 CIV. 57 (PAE),
2016 WL 3773394, at *11 (S.D.N.Y. July 8, 2016) ....................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.20
21 pg
…granted in part .
Defendant is ordered to col l ect all ESI by imaging her
computers and collecting all email and text messages on any
devices in Defendant's possession or to which she has access
that Defendant used between…
giuffre-maxwell
gov.uscourts.nysd.447706.18.0
5 pg
…present” of broad categories such as:
3
All documents relating to your travel from the period 1999 – present,” (No. 8);
All computers, hard drives or copies thereof for all computers in operation
between 1999 – 2002,” (No. 16)…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.20
7 pg
…jena*, genna*) (Doc. # 321-1).
The defense, however, has not run Plaintiff’s name on defense counsel’s entire system of
computers, servers, hard-drives and email accounts, as Plaintiff has requested. Plaintiff’s
Request for Production 12 requested that…
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