…production from Defendant's electronic media. Accordingly, please use IMAP Capable software (or a functional equivalent) to capture all of the sent/received emails from Ms. Maxwell's various email accounts, including but not limited to the following: (1) GMaxl…
…and production from Defendant's electronic media. Accordingly, please use IMAP Capable software (or a functional equivalent) to capture all of the sent/received emails from Ms. Maxwell's various email accounts, including but not limited to the following: (1) …
… Case 1:15-cv-07433-LAP Document 165-1 Filed 05/26/16 Page 2 of 6 Log Privilege …
…obligations1. Indeed, in response to thirty-eight (38) requests for production, the defendant has chosen to produce two emails.2 This represents a willful disregard of her discovery obligations, something this Court should not condone. “Although not unlimited, relevance, for…
…¶ 37. This entirely fabricated story was obviously inserted as the result of the email exchange between Ms. Giuffre and Sharon Churcher in which Ms. Churcher urges Ms. Giuffre to include my name in her manuscript in order to make it…
…Ex. 2, p, 6/34. Shortly thereafter, on March 20, 2011, Churcher emailed Plaintiff explaining to her how she can corroborate a story to tell the FBI – that she was “given to” Prince Andrew. Menninger Decl., Ex. A, p. 8…
…SERVICE I certify that on February 6, 2017, I electronically served this NOTICE OF SERVICE OF RULE 45 SUBPOENA AND NOTICE OF DEPOSITION OF SA.RAH RANSOME via Email on the folJowing: Sigrid S. McCawley Paul G. Cassell Meridith Schultz …
…85 (D. Conn. 2012), fully complied with two previous discovery requests but objected to inspection of its electronic servers to locate emails whose existence was speculative. Ms. Ransome’s second argument, the unremarkable position that witness interviews are covered by…
…a contingency or pro-bono basis.” Defendant’s Combined Motion at 7. Any suggestion of “fabrication” is directly refuted by the multiple pictures and e-mails non-party Ms. Ransome produced – documentary evidence that Defendant fails to discuss in her…
…camera review, Defendant and Mr. Gow previously exchanged emails about how to leak information to the press to discredit Ms. Giuffre by saying that she “cried rape” when she was 14 (GM_00577): From: Ross Gow Sent: Tuesday, February 24…
…¶ 37. This entirely fabricated story was obviously inserted as the result of the email exchange between Ms. Giuffre and Sharon Churcher in which Ms. Churcher urges Ms. Giuffre to include my name in her manuscript in order to make it…
…85 (D. Conn. 2012), fully complied with two previous discovery requests but objected to inspection of its electronic servers to locate emails whose existence was speculative. Ms. Ransome’s second argument, the unremarkable position that witness interviews are covered by…
…Privilege1. For the reasons outlined below, the Court should deny Plaintiff’s Motion to Compel Production of Documents Subject to Improper Privileges. INTRODUCTION Without a single conferral (despite multiple email and telephonic contacts between counsel in the interim weeks), Plaintiff…
…party witness Ms. Ransome, via email and telephone on the issues raised in this motion and has been unable to resolve these issues without court intervention. INTRODUCTION Counsel for Plaintiff, also counsel for non-party witness Sarah Ransome, in mid…
…includes every writing or record of every type and description that is or has been in Your possession, custody or control, or of which You have knowledge, including but not limited to, e- mails, text messages, instant messages, videotapes, photographs…
…which merely said, in every entry, “Communication re: legal advice”), Ms. Giuffre’s entries describe the subject matter of the communication and disclose all individuals on the email chain. Therefore, Defendant has no legitimate basis to challenge Ms. Giuffre’s…
…Filed 05/20/16 Page 1 of 9 EXHIBIT C Case 1:15-cv-07433-LAP Document 156-3 Filed 05/20/16 Page 2 of 9 Pottinger Documents Log Email Sent …
…discovery conduct. Ms. Giuffre has produced over 4,274 pages of documents to date in this case and Defendant has produced two emails.2 Indeed, in light of this Court’s strong words at the hearing on March 17, 2016…
…II”).) DE 173, a declaration, references additional Non-Parties, generally those identified in lawyer emails. The Court may wish to defer consideration of this DE. Redaction of the names would eliminate any issue related to this document. DE 173-1…
…a contingency or pro-bono basis." Defendant's Combined Motion at 7. Any suggestion of "fab1ication" is directly refoted by the multiple pictures and e-mails non-party Ms. Ransome produced - documentaiy evidence that Defendant fails to discuss in her…