giuffre-maxwell
gov.uscourts.nysd.447706.356.0
17 pg
…sister patronage of her art work; he’d promised the
younger funding for a trip abroad that would give her the work experience she needed on
her resume for a place at an Ivy League university, which she desperately wanted …
giuffre-maxwell
gov.uscourts.nysd.447706.315.0
17 pg
…sister patronage of her art work; he’d promised the
younger funding for a trip abroad that would give her the work experience she needed on
her resume for a place at an Ivy League university, which she desperately wanted …
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…academicians.” Id. As Mr. Cassell is well aware, Jeffrey Epstein was heavily
involved in funding academic research at Harvard and kept an office there,3 and he was
consequently friendly with many academics, including David Gergen, Marvin Minsky, Larry
Summers…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.33
12 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.1
8 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…Civ. P. 37(e)(2). The new Rule
37 “rejects cases such as Residential Funding Corp. v. DeGeorge Financial Corp., 306 F.3d 99
8
Case 1:15-cv-07433-LAP Document 1330-16 Filed 01/05/24 Page…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…sister patronage of her art work; he’d promised the
younger funding for a trip abroad that would give her the work experience she needed on
her resume for a place at an Ivy League university, which she desperately wanted …
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…mind’; and
(3) that the missing evidence is ‘relevant’ to the party's claim or defense such that a reasonable
trier of fact could find that it would support that claim or defense.” Id. (citing Residential
Funding Corp. v. DeGeorge…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…sister patronage of her art work; he’d promised the
younger funding for a trip abroad that would give her the work experience she needed on
her resume for a place at an Ivy League university, which she desperately wanted …
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…mind’; and
(3) that the missing evidence is ‘relevant’ to the party's claim or defense such that a reasonable
trier of fact could find that it would support that claim or defense.” Id. (citing Residential
Funding Corp. v. DeGeorge…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.4
27 pg
…academicians.” Id. As Mr. Cassell is well aware, Jeffrey Epstein was heavily
involved in funding academic research at Harvard and kept an office there,3 and he was
consequently friendly with many academics, including David Gergen, Marvin Minsky, Larry
Summers…
giuffre-maxwell
gov.uscourts.nysd.447706.46.0
22 pg
…under the attorney-client privilege and that it be made for the
purpose of furthering a legal interest or strategy common to the parties asserting it.” San Diego
Gas & Elec. Co. v. Morgan Stanley Senior Funding, Inc., No. 150017/15…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…sister patronage of her art work; he’d promised the
younger funding for a trip abroad that would give her the work experience she needed on
her resume for a place at an Ivy League university, which she desperately wanted …
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…dime-a-dozen. As this Court has previously
noted, finding that extraordinary circumstances are present simply
because law enforcement is investigating a matter of great public
interest “would effectively eviscerate the Martindell standard,”
Daniels, 200 F.R.D. at 210…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.19
21 pg
…mind’; and
(3) that the missing evidence is ‘relevant’ to the party's claim or defense such that a reasonable
trier of fact could find that it would support that claim or defense.” Id. (citing Residential
Funding Corp. v. DeGeorge…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.1
17 pg
…sister patronage of her art work; he’d promised the
younger funding for a trip abroad that would give her the work experience she needed on
her resume for a place at an Ivy League university, which she desperately wanted …
giuffre-maxwell
gov.uscourts.nysd.447706.509.0
18 pg
…18
state of mind; and (3) that the destroyed evidence was relevant to the party's claim
or defense such that a reasonable trier of fact could find that it would support that
claim or defense.
Residential Funding Corp. v…
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