…record for Defendant Ghislaine Maxwell (“Maxwell”) in this action. I respectfully submit this declaration in support of Defendant’s Opposition to Plaintiff’s Motion for Forensic Examination. 2. Attached as Exhibit A are true and correct copies of correspondence between …
…1327-9 Filed 01/05/24 Page 3 of 21 Sweet, D.J . Eight discovery motions are currently pending before this court. 1. Plaintiff Virginia Giuffre ("Giuffre" or "Plaintiff") has moved for an order of forensic examination, ECF No. 96…
…Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit) REPLY MEMORANDUM OF LAW in Support re: 96 04/25/2016 121 Motion to Compel MOTION for Clarification of Court's Order and For Forensic …
…Emails exchanged between Mr. Epstein’s attorney and Ms. Maxwell’s attorney. .. 19 III. Plaintiff has failed to establish any ground for an invasive “forensic review” of Ms. Maxwell’s electronic devices. ............................................................................ 20 CONCLUSION ...................................…
…OF NEW YORK --------------------------------------------------X ............................................. VIRGINIA L. GIUFFRE, Plaintiff, v. 15-cv-07433-RWS GHISLAINE MAXWELL, …
…1328-9 Filed 01/05/24 Page 3 of 21 Sweet, D.J. Eight discovery motions are currently pending before this court. 1. Plaintiff Virginia Giuffre ("Giuffreu or "Plaintiffu) has moved for an order of forensic examination, ECF No. 96…
…Ms. Giuffre is entitled to a forensic examination of Maxwell’s personal computers and devices to recover deleted emails and to discovery when and if Maxwell has performed a “swipe” of her computers/devices to permanently destroy deleted emails. Second…
…sexual assault is not only a crime, but a physical injury, and an injury for which medical treatment is needed and for which a forensic medical exam is often performed. Accordingly, any documentation of sexual assault is necessarily akin to…
…other search terms are a tremendous stretch, I can agree to them in the interest of getting the search done on a timely basis. According to our forensic expert, running a search on Ms. Maxwell’s devices of all 368…
…Y . May 2 , 2016). Pl aint i ff filed her mot i on for clarification of the Court ' s March 17 , 2016 Order and for forensic examination on April 13 , 2 016 . By Order dated April 15 , 20 16, the…
…other search terms are a tremendous stretch, I can agree to them in the interest of getting the search done on a timely basis. According to our forensic expert, running a search on Ms. Maxwell’s devices of all 368…
…Ransome did not search any other accounts for responsive communications, no forensic search was conducted of the account, nor did her attorneys conduct a search of her computer (including the attorneys representing her in her Jane Doe complaint). According to…
…Ransome did not search any other accounts for responsive communications, no forensic search was conducted of the account, nor did her attorneys conduct a search of her computer (including the attorneys representing her in her Jane Doe complaint). According to…
…at your opponent's 15 papers. That was the request one, four, five and 14. They say 16 no forensic search, no search. 17 MR. POTTINGER: Your Honor, she has testified that she 18 searched her computer. I'm not…
…s burden under Egiazaryan, it should compel Defendant to produce those documents. F. A Forensic Review is Appropriate in these Circumstances Since filing the instant motion, Defendant has produced another communication between her and Ross Gow, and another email between…
…entries related to motion for adverse inference); ECF Nos. 125, 329 (entries related to motions concerning forensic examination of computer); ECF No. 146 (entries related to brief in support of privilege claimed for Plaintiff's in camera submission); ECF no…
…1219-11 Filed 07/15/21 Page 9 of 13 Case 1:15-cv-07433-LAP Document 1219-11 Filed 07/15/21 Page 10 of 13 Defendant fails to mention that a forensic review would not give Ms…
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