…York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF VIRGINIA GIUFFRE’S MOTION FOR FINDING OF CIVIL CONTEMPT AGAINST SARAH KELLEN FOR IGNORING SUBPOEN…
…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…
…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…
…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…
…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…
…Personal Service, which this Court granted on June 20, 2016; DE 308, Motion for Finding Civil Contempt against Sarah Kellen for Ignoring Subpoena (pending); DE 310, Motion for Finding of Civil Contempt against Nadia Marcinkova for Ignoring Subpoena (pending). Similarly…
…about the Non-Parties that could warrant sealing. Alternatively, if the Court finds upon review that a document contains no sensitive information about a yet-to-be-noticed Non-Party, or if the document contains only publicly available information about…
…the motion is denied; and (4) any 5 Case 1:15-cv-07433-LAP Document 1111 Filed 09/01/20 Page 6 of 14 unusual circumstances militating for or against a finding of timeliness.’” D’Amato v. Deutsche Bank…
…Conn. 1993) (finding deposition inadmissible because” motive for investigation in the deposition was not the same as motive for cross– examination at trial”). Indeed, a clear illustration of the fact that the attorneys deposing Dershowitz had little incentive to develop…
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