gov.uscourts.nysd.447706.1058.1.pdf PDF
…Preska June 12, 2020 Page 2 of 3 Plaintiff put her reputation (which she contended was destroyed by Ghislaine Maxwell) and her damages at issue in Maxwell. Dershowitz is e…
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gov.uscourts.nysd.447706.1071.0.pdf PDF
…case are not properly in possession of Plaintiff Virginia Giuffre’s (“Ms. Giuffre”) current counsel and thus must be destroyed under the plain terms of the Maxwell protective order. 1. The Maxwell Protective Order At the heart of the dispute…
gov.uscourts.nysd.447706.958.3.pdf PDF
…which have been designated as CONFIDENTIAL shall be returned to the party that designated it CONFIDENTIAL, or the parties may elect to destroy CONFIDENTIAL documents,” whereupon an affidavit confirming destruction must be provided. Since the conclusion of the Giuffre matter…
gov.uscourts.nysd.447706.555.0.pdf PDF
…w emgries and events .. Rather than having her new story impeached by her own words, she destroyed the unfavorable evidence. Such willful and intentional destruction of evidence I warrants an adverse inference jury instruction, if not outright dismissal of Plaintiff…
gov.uscourts.nysd.447706.35.0.pdf PDF
…Ms. Giuffre is entitled to a forensic examination of Maxwell’s personal computers and devices to recover deleted emails and to discovery when and if Maxwell has performed a “swipe” of her computers/devices to permanently destroy deleted emails. Second…
gov.uscourts.nysd.447706.1325.1.pdf PDF
…evidence in this case. 2 In actuality, the only journal Plaintiff ever maintained that might contain relevant information was purposefully destroyed by Plaintiff in a bonfire in 2013, at a time when she was represented by counsel and actively trying…
gov.uscourts.nysd.447706.1069.0.pdf PDF
…from 20 whom discovery was sought and obtained in the Maxwell matter, 21 didn't rely on the promises made in the protective order that 22 the materials would be destroyed or returned at the conclusion 23 of that case…
gov.uscourts.nysd.447706.1332.17.pdf PDF
…Materials”). The Protective Order prohibits the use of the materials in any other case, and requires the parties to return or destroy the materials at the conclusion of this case. This case concluded in May 2017. Despite our requests, Ms…
gov.uscourts.nysd.447706.1062.0.pdf PDF
…confidential materials will remain so designated through “the conclusion of the case,” at which time they will be returned to the designating party or destroyed. Dershowitz makes the unremarkable observation that the Protective Order contains generic language permitting future modifications…
gov.uscourts.nysd.447706.46.0.pdf PDF
…but also Plaintiff’s knowledge of said representations. Plaintiff claims that the presence of Ms. Maxwell’s agent Ross Gow on communications with her attorney destroyed the privilege, despite binding New York law to the contrary. Plaintiff asserts that Ms…
gov.uscourts.nysd.447706.20.0.pdf PDF
…the president of a non-profit corporation designed to help victims of sex trafficking, and inasmuch as they destroyed her credibility and reputation among members of the community that seek her help and that she seeks to serve.” Complaint ¶ 11…
gov.uscourts.nysd.447706.962.0.pdf PDF
…motions concerns the materials at issue in Ms. Maxwell’s show- cause motion. That motion seeks relief for Ms. Giuffre’s lawyers’ “refus[al] to return or destroy Confidential Materials,” Doc.957, at 1, in their possession, custody and control…
gov.uscourts.nysd.447706.957.0.pdf PDF
…Materials”). The Protective Order prohibits the use of the materials in any other case, and requires the parties to return or destroy the materials at the conclusion of this case. This case concluded in May 2017. Despite our requests, Ms…
gov.uscourts.nysd.447706.965.0.pdf PDF
…s, 14 and was dismissed shortly thereafter. Two times since May we 15 have asked for agreed upon protocol with the plaintiff's 16 counsel to finish up destroying or exchanging-back confidential 17 documents. The first request was shortly…
gov.uscourts.nysd.447706.1332.16.pdf PDF
…however am not intimated and need your help. These men distroyed my life. I apologize for my heated first email to you however when I came across your acticle in the NYC Post, how that happened I don't know…
gov.uscourts.nysd.447706.1330.5.pdf PDF
…error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved 1 …
gov.uscourts.nysd.447706.967.0.pdf PDF
…proh i bited from disclosing such materials to non - parties except on certain conditions , and (b) required at the conclusion of the case to return or destroy each document and all copies of these Confidentia l Ma t erials. Id …
gov.uscourts.nysd.447706.1206.13.pdf PDF
…conclusively establishing the privacy of Maxwell’s deposition testimony. Indeed, under the plain terms of the Protective Order, were required to return or destroy all confidential information at the conclusion of the case, including Maxwell’s deposition transcripts. refused to…
gov.uscourts.nysd.447706.1206.2.pdf PDF
…upon, each document and all copies thereof which have been designated as CONFIDENTIAL shall be returned to the party that designated it CONFIDENTIAL, or the parties may elect to destroy CONFIDENTIAL documents. Where the parties agree to destroy CONFIDENTIAL documents…
gov.uscourts.nysd.447706.1328.28.pdf PDF
…it. After being notified, a party must promptly return, sequester, or destroy the specified (3) Quashing or Modifying a Subpoena. infonnation and any copies it has; must not use or disclose the information (…
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