…During that time, Plaintiff has had a full and fair opportunity to depose Ms. Maxwell on the subject matters she claims are raised by these two emails, and Plaintiff did in fact question Ms. Maxwell on the subjects covered by…
…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…
…Wednesday, July 13, 2016 8:22 PM To: Jeff Pagliuca Subject: Fwd: Your motions Jeff, Look I'm not going to be dragged into these nonsense emails. I'm willing to help clear up miscommunication if that indeed occurred. However…
…in determining whether nonparty witness’ invocation of privilege against self-incrimination in course of civil litigation and 9 In discovery, Defendant Maxwell has produced several emails between Epstein and herself discussing Ms. Giuffre. 8 Case 1:15-cv-07433…
…at pp. 20- 8 In discovery, Defendant Maxwell has produced several emails between Epstein and herself discussing Ms. Giuffre. 7 Case 1:15-cv-07433-LAP Document 1256-11 Filed 05/03/22 Page 12 of 15 22), the…
…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…
…should not be filed publicly with Doe 1’s name unredacted. (See Def. Letter at 2.) The Court has already declined to construe the emails from Does 1 and 2 that Defendant refers to as formal objections (Order, dated Oct…
…Court Order regarding Forensic Examination of Devices, as follows: INTRODUCTION Defense counsel has already run the amended list of search terms proposed by Plaintiff on each applicable device and as to each email account to which Ms. Maxwell has access…
…forensic examination is unnecessary. Lastly, Ms. Maxwell’s representation that “prior to this litigation” she has long had a practice of deleting emails after they have been read does not warrant a forensic examination. First, prior to this litigation, Ms…
…every custodian interview conducted, the individual was asked about peripheral drives and devices and counsel were told (A) that the individual does not use those devices for business matters or (B) that where emails are concerned, the emails on those…
…at Composite Exhibit 5, May 2016 Emails from Meredith Schultz to Laura Menninger. 4 Case 1:15-cv-07433-LAP Document 1325-7 Filed 01/04/24 Page 9 of 30 Additionally, Defendant’s motion lists 15 providers 8…
…Court Order regarding Forensic Examination of Devices, as follows: INTRODUCTION Defense counsel has already run the amended list of search terms proposed by Plaintiff on each applicable device and as to each email account to which Ms. Maxwell has access…
…at Composite Exhibit 5, May 2016 Emails from Meredith Schultz to Laura Menninger. 4 Case 1:15-cv-07433-LAP Document 1325-14 Filed 01/04/24 Page 9 of 30 Additionally, Defendant’s motion lists 15 providers9 Ms…
…Giuffre could provide more detail on these issues, which are documented in numerous back and forth emails between the parties; but rather than inundate the Court with those issues, 4 Case 1:15-cv-07433-LAP Document 199 Filed…
Case 1:15-cv-07433-LAP Document 1099 Filed 08/10/20 Page 1 of 4 Sigrid S. McCawley Telephone: (954) 356-0011 E…
Case 1:15-cv-07433-LAP Document 1232 Filed 10/29/21 Page 1 of 3 Sigrid S. McCawley Telephone: (954) 356-0011 …
…employment (RFP 28), and any person to whom she gave a massage (RFP 29). Ms. Maxwell conducted a thorough search of her email systems and her devices prior to her production on February 8, 2016. All documents identified as responsive…
…employment (RFP 28), and any person to whom she gave a massage (RFP 29). Ms. Maxwell conducted a thorough search of her email systems and her devices prior to her production on February 8, 2016. All documents identified as responsive…
…com r 11- ·~ ~u-~·7 j ,-:..~ ~ ·s I ; I February 21, 2017 …
…Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: [email protected] [email protected] /s/ Sigrid S.…