…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. …
… Case 1:15-cv-07433-LAP Document 1330-23 Filed 01/05/24 Page 2 of 9 produced documents at issue in this pending motion is an email chain showing Epstein’s involvement in crafting yet another draft statement…
…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…
…Defendant. ________________________________/ PLAINTIFF MS. GIUFFRE’S RENEWED MOTION TO COMPEL DATA FROM DEFENDANT’S UNDISCLOSED EMAIL ACCOUNT AND FOR AN ADVERSE INFERENCE INSTRUCTION Ms. Giuffre hereby files a Renewed Motion to Compel Data from Defendant’s Undisclosed Email Accounts and for…
…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…
…York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S MOTION TO COMPEL DATA FROM DEFENDANT’S UNDISCLOSED EMAIL ACCOUNT AND FOR AN ADVERSE INFERENCE INSTRUCTION Plaintiff, Virginia …
…York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S MOTION TO COMPEL DATA FROM DEFENDANT’S UNDISCLOSED EMAIL ACCOUNT AND FOR AN ADVERSE INFERENCE INSTRUCTION Plaintiff, Virginia …
…Plaintiff’s motion is granted in part. Defendant is ordered to collect all ESI by imaging her computers and collecting all email and text messages on any devices in Defendant’s possession or to which she has access that Defendant…
…simply implausible, as a review of Defendant’s interactions with several of the important players in this case makes clear. i. : Q. And then below there is an email from to you and cc'ing on January 11, 2015. Do…
…York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S MOTION TO COMPEL DATA FROM DEFENDANT’S UNDISCLOSED EMAIL ACCOUNT AND FOR AN ADVERSE INFERENCE INSTRUCTION Plaintiff, Virginia …
…simply implausible, as a review of Defendant’s interactions with several of the important players in this case makes clear. i. : Q. And then below there is an email from to you and cc'ing on January 11, 2015. Do…
…that she used Mr. Gow in 2011 in relation to Ms. Giuffre’s claims: Q. And then below there is an email from Philip Barden to you and cc'ing Ross Gow on January 11, 2015. Do you see that? …
…York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S MOTION TO COMPEL DATA FROM DEFENDANT’S UNDISCLOSED EMAIL ACCOUNT AND FOR AN ADVERSE INFERENCE INSTRUCTION Plaintiff, Virginia …
…Plaintiff’s motion is granted in part. Defendant is ordered to collect all ESI by imaging her computers and collecting all email and text messages on any devices in Defendant’s possession or to which she has access that Defendant…
… (See dkt. nos. 1123-24.) Those letters concern an email sent on September 25, 2020, by Does 1 and 2 to the Court and to the parties (1) stating that Doe 1 and Doe 2 did not generally object to…
…401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 Tel: (954) 356-0011 Email: [email protected] David Boies Boies, Schiller & Flexner LLP …
…401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 Tel: (954) 356-0011 Email: [email protected] David Boies Boies, Schiller & Flexner LLP …
…of the documents. For example, if the search term is “acuity,” “hits” should include all the document that include the word “acuity” in their text OR in their metadata (this includes words in items such as email subjects, filenames, as …
…401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 Tel: (954) 356-0011 Email: [email protected] David Boies Boies, Schiller & Flexner LLP …