…Dear Ms. Menninger, Attached please find correspondence from Meredith Schultz in regards to the above-referenced matter. Please do not hesitate to contact our office should you have any questions regarding this matter. Thank You, Aneisha K.Christie BOIES, SCHILLER…
…com Re: Giuffre v. Maxwell, Case No. 15-cv-07433-RWS Dear Sigrid: Attached please find documents produced pursuant to a subpoena duces tecum issued to Mar-a-Lago Club, Inc., on July 14, 2016 which have been Bates numbered …
…Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ____________________________/ DECLARATION OF MEREDITH SCHULTZ IN SUPPORT OF PLAINTIFF VIRGINIA GIUFFRE’S MOTION FOR FINDING OF CIVIL CONTEMPT AGAINST NADIA MARCINKOVA FOR IGNORING SUBPOENA AND FOR ASSOCIATED SANCTIONS…
…C ou rt’s A pril21,2016,ru lingM s.Giu ffre has mad e significantefforts to try to trackd own and collectany med icalrecord she can find from 1999 to the present,inclu d ingpayingall fees associated withthatcollection process…
… and relatedly, that Does 1 and 2 are (for now) proceeding pro se further counsels in favor of a finding that the September 25 Email is not a formal objection for purposes of Paragraph 2(d) of the Protocol. Here…
…September 2001. Additionally, the Pew Research Center published findings that certain demographics have higher internet usage, including many demographics to which Defendant belongs. For example, higher rates of internet usage are found among younger adults (Defendant was 38 in 1999…
…September 2001. Additionally, the Pew Research Center published findings that certain demographics have higher internet usage, including many demographics to which Defendant belongs. For example, higher rates of internet usage are found among younger adults (Defendant was 38 in 1999…
…Palm Beach County State Attorney’s Office, Public Records Request No.: 16-268, Disc 7 (GIUFFRE007590) at Page 2305. Upon finding this undisclosed email accounts, the undersigned sent a follow-up letter to Ms. Menninger, stating: “please include a search…
…September 2001. Additionally, the Pew Research Center published findings that certain demographics have higher internet usage, including many demographics to which Defendant belongs. For example, higher rates of internet usage are found among younger adults (Defendant was 38 in 1999…
…September 2001. Additionally, the Pew Research Center published findings that certain demographics have higher internet usage, including many demographics to which Defendant belongs. For example, higher rates of internet usage are found among younger adults (Defendant was 38 in 1999…
…2 Filed 01/27/21 Page 3 of 10 I also wanted to point out another special syntax with regard to proximity searching. This is a search that finds words within a specified distance from one another. On some software…
…Hearing Transcript at pg. 24:1-7. Ms. Giuffre believes that her submission for in camera review complies with this Court’s Order. To the extent the Court finds that Ms. Giuffre has misinterpreted the Court’s order, Ms. Giuffre …
…Reply
…our representations during the March 21, 2016 meet and confer phone call, we are working diligently to find information to supplement the below information with regard to address and dates, and once that information is obtained, Plaintiff will serve supplemental…
…which now permits an adverse inference instruction only when the court finds that a spoliating party purposefully and willfully destroys evidence and that party “acted with the intent to deprive another party of the information's use in the litigation…
…call on July 26, 2016, counsel for Ms. Giuffre asked Defendant to run Ms. Giuffre’s name as a search term to find documents responsive to (for example) Ms. Giuffre’s Request No. 12, which sought Defendant’s documents relating…
…him? 21 employing you 7 21 A. No. 22 A. No, they said they' re going to find out 22 Q. It was through somebody else? 23 and obviously the first thing they did was talk to 23 A. Ms…
…plus I just like working with someone I can somewhat trnst, which is a rare find in thi s world! But if they're selling something this headline worthy and going to sell many papers and not to mention the…
…call on July 26, 2016, counsel for Ms. Giuffre asked Defendant to run Ms. Giuffre’s name as a search term to find documents responsive to (for example) Ms. Giuffre’s Request No. 12, which sought Defendant’s documents relating…
…our representations during the March 21, 2016 meet and confer phone call, we are working diligently to find information to supplement the below information with regard to address and dates, and once that information is obtained, Plaintiff will serve supplemental…
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