…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 …
…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…
…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…
…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…
…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…
…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…
…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 for various other reasons. She did not say any of…
…Instead, Defendant’s brief quotes extensively from cases in which parties destroyed evidence after the cause of action accrued and after the parties had notice of a duty to preserve. Those are inapposite. Because this is a losing argument for…
…were published intentionally for the malicious purpose of further damaging a sexual abuse and sexual trafficking victim; to destroy Giuffre’s reputation and credibility” and that Defendant “made her false statements knowing full well that they were completely false. Accordingly…
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