giuffre-maxwell
gov.uscourts.nysd.447706.125.0
1 pg
…Order
Dear Judge Sweet:
This is a letter motion to file Ms. Giuffre's Non-Redacted Reply in Support of Motion for
Forensic Examination ("Reply Brief') and certain accompanying exhibits under seal pursuant to
this Court's March 18, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.3_2
12 pg
…4 https://www.npr.org/2020/10/22/926590153/jeffrey-epstein-update-read-the-deposition-that-ghislaine-maxwell-fought-to-hide
5 https://www.insider.com/ghislaine-maxwell-deposition-forensic-psychologist-analysis-2020-10
6 https://www.youtube.com/watch…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…multiplying these proceedings and
misstating the record. In what amounts to the fourth Motion on forensic examination of Ms.
Maxwell’s computers and email accounts, Plaintiff now trumps up a claim that some unidentified
and “undisclosed” email account should have…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.8_1
3 pg
…to spend every Thursday at noon in New York before the Court for no reason. We are in the
process of the forensic examination of the devices. We expect to have that examination completed prior to Ms.
Maxwell's continued…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.19
21 pg
…x Plaintiff’s Response in Opposition to Defendant’s Motion for a Protective Order
Regarding Defendant’s Deposition (DE 70) - Defendant’s Motion Denied (DE 106).
x Plaintiff’s Motion for Forensic Examination (DE 96) - Granted in part (June 20…
giuffre-maxwell
gov.uscourts.nysd.447706.111.2
5 pg
…product. The
private and confidential records which may exist on Plaintiff’s laptop have no bearing on the
claims at bar.
Defendant’s motion to conduct a forensic examination of Plaintiff’s Rugged TBT Drive and
laptop is DENIED, at…
giuffre-maxwell
gov.uscourts.nysd.447706.288.1
4 pg
…you would have learned that the devices have been sent to Denver to our
forensic consultant for imaging and searching and that to the extent any responsive documents exist we
intend to get them to you as soon as possible…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…multiplying these proceedings and
misstating the record. In what amounts to the fourth Motion on forensic examination of Ms.
Maxwell’s computers and email accounts, Plaintiff now trumps up a claim that some unidentified
and “undisclosed” email account should have…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.16
30 pg
…to produce. Ms. Giuffre had to
bring a Motion for Forensic Examination and the Court had to order that Defendant’s counsel
actually produce documents from Defendant’s electronic documents, something that has not yet
been done to date. Indeed…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.7
30 pg
…to produce. Ms. Giuffre had to
bring a Motion for Forensic Examination and the Court had to order that Defendant’s counsel
actually produce documents from Defendant’s electronic documents, something that has not yet
been done to date. Indeed…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.5_2
30 pg
…to produce. Ms. Giuffre had to
bring a Motion for Forensic Examination and the Court had to order that Defendant’s counsel
actually produce documents from Defendant’s electronic documents, something that has not yet
been done to date. Indeed…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.19
30 pg
…to produce. Ms. Giuffre had to
bring a Motion for Forensic Examination and the Court had to order that Defendant’s counsel
actually produce documents from Defendant’s electronic documents, something that has not yet
been done to date. Indeed…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.12_3
30 pg
…to produce. Ms. Giuffre had to
bring a Motion for Forensic Examination and the Court had to order that Defendant’s counsel
actually produce documents from Defendant’s electronic documents, something that has not yet
been done to date. Indeed…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.11
13 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.70.0
15 pg
…discovery,
Plaintiff retained an electronic discovery and litigation support firm, Rational Retention, to
assist with the forensic searching and producing of responsive electronic files in this case.
4
Rational Retention performed, as part of their contract, de-duping services…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.14
30 pg
…to produce. Ms. Giuffre had to
bring a Motion for Forensic Examination and the Court had to order that Defendant’s counsel
actually produce documents from Defendant’s electronic documents, something that has not yet
been done to date. Indeed…
Comments