…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…
…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…
…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…
…2 MS. MENNINGER: Your Honor, I actually believe that 3 these emails were some that your Honor had reviewed because we 4 had asserted a joint defense agreement privilege, and your 5 Honor reviewed these emails, and they were produced…
…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 …
…documents, particularly electronic documents, dating back over 16 years. However, Ms. Maxwell, prior to this litigation has long had a practice of deleting emails after they have been read. 17. Ms. Maxwell objects to Instruction Nos. 5, 8, 9, 12…
…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…
…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…
…documents, particularly electronic documents, dating back over 16 years. However, Ms. Maxwell, prior to this litigation has long had a practice of deleting emails after they have been read. 17. Ms. Maxwell objects to Instruction Nos. 5, 8, 9, 12…
…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 …
…documents, particularly electronic documents, dating back over 16 years. However, Ms. Maxwell, prior to this litigation has long had a practice of deleting emails after they have been read. 17. Ms. Maxwell objects to Instruction Nos. 5, 8, 9, 12…
…these documents to any particular time period or topic, instead requiring Churcher to sift through a decade’s worth of communications, from multiple email accounts with multiple employers. The Subpoena must be quashed for two separate and independent reasons. First…
…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…
…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…
…2020. The excerpt request was accompanied by an email indicating that Does 1 and 2 “do not object to the unsealing” but “ask that [they] are not identified by name.” Because the email incorporates (a) an excerpt request, (b) a…
…book she was writing 25 that you helped sell to the press, as if it Page 361 1 G Maxwell - Confidential 2 (Maxwell Exhibit 17, email, marked 3 for identification.) 4 Q. This is an email from you on…
…150 East 10th Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: [email protected] [email protected] Copies of this filing were also provided by e-mail to: Marty Weinberg, counsel for Jeffrey Epstein Bruce…
…as Maxwell 17. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1330-19 Filed 01/05/24 Page 10 of 15 Page 361 1 G Maxwell - Confidential 2 (Maxwell Exhibit 17, email, marked 3 for identi…