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.447706.207.0
7 pg
…Previously, however, Plaintiff’s
counsel communicated that that it appears that Microsoft deleted the live.com email account for
inactivity, and that Ms. Giuffre has lost access to her Hotmail.com account (multiple password
1
Case 1:15-cv…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.43
12 pg
…She could
have disclosed the domain name of that account. She did not. She could have explained that she
deleted her account; that her account had been destroyed by the provider; or that she can no
longer access her account…
giuffre-maxwell
gov.uscourts.nysd.447706.96.0
15 pg
…didn’t believe this dialogue was
“appropriate.” Defendant’s refusal necessitates a forensic review of her electronic data in order
to ensure that Defendant is not wrongfully withholding discoverable material.5
Defendant has also declared that she regularly deletes documents…
giuffre-maxwell
gov.uscourts.nysd.447706.408.0
13 pg
…. . or
affidavits supported in support [of] the relevancy of discovery requests.” DE 324 at 8 (emphasis
deleted).
16. In a later supplemental order, Judge Marra stated that the victims “may re-refile
these documents omitting the stricken portions.” DE 325…
giuffre-maxwell
gov.uscourts.nysd.447706.218.0
25 pg
…Ct.
N.Y. Cty. 2001) (ellipses omitted and text deleted from quotation restored)); see also O’Neill, 71
N.Y.2d at 527 (the material sought must be “essential to the maintenance of the litigant’s
claim”).5 By definition…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.13
2 pg
…are not the intended recipient, do not read, use, disseminate, distribute or copy this message or
attachments. If you have received this message in error, please notify the sender immediately and delete this message
together with any attachments.
…
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.447706.1326.2
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.447706.1100.1
13 pg
…has been made part of
the record of this case, Defense Counsel shall return to the
Government or securely destroy or delete all Discovery,
including but not limited to Confidential Information, within 30
days of the expiration of the period…
giuffre-maxwell
gov.uscourts.nysd.447706.1100.0
16 pg
…has been made part of
the record of this case, Defense Counsel shall return to the
Government or securely destroy or delete all Discovery,
including but not limited to Confidential Information, within 30
days of the expiration of the period…
giuffre-maxwell
gov.uscourts.nysd.447706.993.0
28 pg
…If you have received this transmission in error, please notify
the sender by telephone or return e‐mail and delete the original transmission and its attachments without reading or
saving it in any manner. Thank you.
1
Case 1:15…
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