…McCawley; Jeff Pagliuca; Brad Edwards; Paul Cassell ([email protected]) Subject: RE: Conferral regarding forensic search Follow Up Flag: Follow Up Flag Status: Flagged Laura, Please see my additions in-line, in black, below to your email sent yesterday…
…York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ______________________________/ PLAINTIFF VIRGINIA GIUFFRE’S MOTION FOR CLARIFICATION OF COURT’S ORDER AND FOR FORENSIC EXAMINATION …
…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…
… 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). Plaintiff’s Motion for Forensic Examination (DE 96) - Granted in part (June 20…
…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…
…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 ...................................…
…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…
…Compliance Non-Parties who have objected to unsealing or whose time to With Court Order object to unsealing has not yet expired. Concerning Forensic Examination Of Devices 321 Retain redaction of email address. …
…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…
…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…
…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…
…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…
…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…
…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…
…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…