…care providers and produce their records prior to her deposition, despite this Court’s order .................................................................... 3 B. Plaintiff failed to produce emails form her iCloud and hotmail accounts ....................... 6 C. Plaintiff has failed to produce…
…THE SUBPOENA TO APPLE, INC. SEEKING PRODUCTION OF ALL OF MS. GIUFFRE’S SENT AND RECEIVED EMAILS AND RELATED DATA Plaintiff Virginia Giuffre, by and through her undersigned counsel, hereby files this motion for a protective order, barring enforcement of…
…publicly disclosed volumes of information related to her allegations, to claim that letters or emails from her lawyers or other documents sent to any law enforcement agency are protected by any privilege. Plaintiff lacks standing to raise the issue and …
…past and ongoing legal matters both before and after April 2015. I regularly communicated with Mr. Epstein regarding my legal representation of him via email with the intention that such email communications remain confidential and privileged. As counsel for Mr…
…to as to specific past and ongoing legal matters both before and after April 2015. I regularly communicated with regarding my legal representation of via email with the intention that such email communications rema…
…Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S MOTION FOR A PROTECTIVE ORDER REGARDING THE SUBPOENA TO MICROSOFT CORPORATION SEEKING PRODUCTION OF ALL OF MS. GIUFFRE’S SENT AND RECEIVED EMAILS AND RELATED DATA Plaintiff Virginia Giuffre, by and through her undersigned counsel…
…deposition will not exceed a total of four hours. The two separate issues relate to (1) Defendant’s failure to answer certain questions at her deposition and (2) her late production of important emails. These two issues developed as follows. …
…the Protective Order in giving testimony and producing documents including evidence of assault, medical records, and emails,” and “[t]hird-party witnesses have done the same.” Doc.892, at 6-7. “Protection of confidential discovery in this case is appropriate,”…
…in the event of an unsealing order, to permit the release of certain emails to avoid a situation where selective and one-side unsealing of deposition testimony occurs, and information is released in a manner that is decontextualized and unfair…
…Nov. 2, 2016 at 7. During the hearing on November 10, 2016, this Court granted Plaintiff’s Motion to permit this third deposition to include questioning concerning two emails produced August 16, 2016 (Doc. # 466); see Tr. of Nov. 10…
…A. Menninger HADDON MORGAN 150 East 10th Avenue FOREMAN Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 …
…Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S REPLY IN SUPPORT OF MOTION TO COMPEL DATA FROM DEFENDANT’S UNDISCLOSED EMAIL ACCOUNT AND FOR AN ADVERSE INFE…
…the Ransome deposition—an action that would require modification of the Protective Order in this case —it also simultaneously remove the confidentiality designation from several related emails and attachments that the parties previously designated confidential (RANSOME_000273-557) (“the Emails”)…
…authorized to accept service conditioned on the deposition being located near Mr. Epstein's Virgin Island residence which you indicated in your email of May 25 was acceptable to you, on a date and location (close to but not at…
…matter was deemed fully c submitted. ·. II. The J?riv;i.l.ege Claim$ at l$l?rie : Defendant has withheld 99 pages of emails with communications involving various combinations of Brett Jaffe, Esq. ("Jaffe"), Mark Cohen, Esq. …
…7-9. 1. Mr. Dershowitz moved to unseal portions of a brief filed in connection with a motion to quash, discrete emails filed with the motion, and the manuscript of Ms. Giuffre’s memoir filed with another motion. Doc.364…
…records and bank account numbers; (ii) personally identifiable information, such as a social security numbers, home addresses, personal email addresses or personal telephone numbers; (iii) protected health information, inclusive of physical and mental health records; and (iv) identifying information of…
…August 2016, Intervenor Alan Dershowitz ("Dershowitz") requested unsealing of portions of a brief filed in connection with a motion to quash, discrete emails filed with the motion, and the manuscript of Giuffre 's memoir filed with another motion. See ECF…
…9, 2016 Order. The Court is now in possession of three additional documents that Defendant failed to produce in contravention of this Court’s Order, in addition to the emails (emails that included among them that Defendant wrongfully withheld. So…
…173-4, 173-10, which Maxwell argues are not judicial documents because they contain “various back and forth emails between counsel.” Maxwell Mem. at 11-12. These docket entries are already available to the public in full on the docket…