…Plaintiff’s Intentional Destruction of Evidence and states as follows: INTRODUCTION All of Plaintiff’s hyperbole and indignation cannot change the simple fact that Plaintiff willfully and intentionally She then either lost a destroyed …
…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…
…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…
…documents SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 Case 1:15-cv-07433-LAP Document 587 Filed 02/02/17 Page 3 of 10 3 H1j6giua 1 that were destroyed. There are two sets of documents that 2…
…of her story contained in the CVRA litigation differed materially from Rather than having her new story impeached by her own words, she destroyed the unfavorable evidence. Such willful and intentional destruction of evidence warrants an adverse inference jury instruction…
…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…
…as a witness in the CVRA action, her duty to preserve this evidence attached. She then either lost a destroyed a second relevant journal after the commencement of this litigation. The intentional destruction of this evidence, regardless of the motive…
…957), and states as follows. INTRODUCTION1 Ms. Maxwell has argued that counsel for Ms. Giuffre have been ordered by this Court to immediately destroy certain materials covered by the protective order in this matter. Counsel for Mr. Giuffre stand ready…
…These two appeals involve some of the confidential documents that you are, apparently, proposing may need to be destroyed now. Until those appeals have been resolved, it would be premature to begin implementing paragraph 12’s provision. We will contact…
…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…
…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…
…2009) (“Where a party violates a court order—either by destroying evidence when directed to preserve it or by failing to produce information because relevant data has been destroyed—Rule 37(b) of the Federal Rules of Civil Procedure provides…
…All while knowing he was HIV positive: Decadence …
…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…
…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…
…2009) (“Where a party violates a court order—either by destroying evidence when directed to preserve it or by failing to produce information because relevant data has been destroyed—Rule 37(b) of the Federal Rules of Civil Procedure provides…
…2009) (“Where a party violates a court order—either by destroying evidence when directed to preserve it or by failing to produce information because relevant data has been destroyed—Rule 37(b) of the Federal Rules of Civil Procedure provides…
…which now permits an adverse inference instruction only when the court finds that a spoliating party purposefully and willfully destroys evidence and that party “acted with the intent to deprive another party of the information's use in the litigation…
…the sole purpose of enabling Defendant and others to communicate with Jeffrey Epstein - has no communications with Epstein or the other co-conspirators, is extremely strong indicia that someone destroyed those email communications. Their destruction warrants an adverse inference instruction…
…2009) (“Where a party violates a court order—either by destroying evidence when directed to preserve it or by failing to produce information because relevant data has been destroyed—Rule 37(b) of the Federal Rules of Civil Procedure provides…
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