giuffre-maxwell
gov.uscourts.nysd.447706.958.2
2 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.33
12 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.1
8 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.19
21 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.468.0
12 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.279.0
8 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.28_4
5 pg
…com, and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
PRIVILEGED GM 001087
CONFIDENTIAL
Case 1:15-cv-07433-LAP Doc…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.5
2 pg
…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
…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.22
22 pg
…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
PRIVILEGED GM_001062
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…and the basis for ii. After being
notified, a par1y must promptly retum, scqUC$ter, or destroy the specified
(A) When Required. On timely !ftOtion, the court for the district where lnfonnation and any copies it has; must not use or…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.9
6 pg
…received this
communication in 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
2
…
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