giuffre-maxwell
gov.uscourts.nysd.447706.96.0
15 pg
…deletion programs on her computer, and the
date they were run, including but not limited to, evidence of “wipes” of Defendant’s
hard drive.
Specifically, Ms. Giuffre’s counsel requests that the Court order a neutral, third party
forensic examiner…
giuffre-maxwell
gov.uscourts.nysd.447706.121.0
10 pg
…after that point and up until this
litigation began. Additionally,
A forensic expert could possibly recover Defendant’s “deleted” e-mail and
could possibly identify when Defendant’s hard drive was wiped. Recovery of deleted material is
critical in this…
giuffre-maxwell
gov.uscourts.nysd.447706.18.0
5 pg
…to your travel from the period 1999 – present,” (No. 8);
All computers, hard drives or copies thereof for all computers in operation
between 1999 – 2002,” (No. 16);
All telephone records associated with you, including cell phone records from
…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.20
7 pg
…however, has not run Plaintiff’s name on defense counsel’s entire system of
computers, servers, hard-drives and email accounts, as Plaintiff has requested. Plaintiff’s
Request for Production 12 requested that “You” (defined as Ms. Maxwell or her…
giuffre-maxwell
gov.uscourts.nysd.447706.944.0
11 pg
…in the functioning of the particular process in question.” Id. (emphasis supplied).
The second approach considers the extent to which the judicial documents are derived from or
are a necessary corollary of the capacity to attend the relevant proceedings. Id…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.1_1
7 pg
…him.
18 It actually happened at one of Jeffrey's residences.
19 (Ms. McCawley left the deposition.)
20 A So it's very hard for me to
21 chronologically give you each person individually.
22 Q (BY MS. MENNINGER) Okay…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…Court failed to conduct the requisite particularized review
when ordering the sealing of the materials at issue. At the same time,
we recognize the potential damage to privacy and reputation that may
accompany public disclosure of hard‐fought, sensitive litigation…
giuffre-maxwell
gov.uscourts.nysd.447706.79.1
12 pg
…this telephonically.
6 Let me just say about telephone motions and
7 conferences, they're terrible because I can't -- you cannot see
8 me frown and it is very hard for me to control counsel by
9 telephone. However…
giuffre-maxwell
gov.uscourts.nysd.447706.82.0_2
11 pg
…this telephonically.
6 Let me just say about telephone motions and
7 conferences, they're terrible because I can't -- you cannot see
8 me frown and it is very hard for me to control counsel by
9 telephone. However…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…Court failed to conduct the requisite particularized review
when ordering the sealing of the materials at issue. At the same time,
we recognize the potential damage to privacy and reputation that may
accompany public disclosure of hard‐fought, sensitive litigation…
giuffre-maxwell
gov.uscourts.nysd.447706.978.0
27 pg
…Court failed to conduct the requisite particularized review
when ordering the sealing of the materials at issue. At the same time,
we recognize the potential damage to privacy and reputation that may
accompany public disclosure of hard‐fought, sensitive litigation…
giuffre-maxwell
gov.uscourts.nysd.447706.977.0
27 pg
…Court failed to conduct the requisite particularized review
when ordering the sealing of the materials at issue. At the same time,
we recognize the potential damage to privacy and reputation that may
accompany public disclosure of hard‐fought, sensitive litigation…
giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…is
irrelevant. How hard the parties worked to designate transcripts has zero relevance to whether a
court submission is a judicial document or what level of presumption of access it should be
afforded.
VI. Category 6: Filings related to third…
giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…to her own domain name) in one location but not another;
shortly afterward hackers breached the host computer.
It would be hard to overstate the “media’s” interest in this case. By “media” we
include all constituents of the twenty…
giuffre-maxwell
gov.uscourts.nysd.447706.1069.0
25 pg
…frankly, hard to imagine that the
7 overlap is so significant that every single piece of paper,
8 every single filing, every single page of discovery material is
9 relevant in one case simply because it exists in the other…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…Document 363-11 Filed 08/11/16 Page 7 of 40
FROM THE ABOVE THE LAW NETWORK
2016 Top Law Firm Gender Your Next Client Wants You Can’t Control Your
Transactional Law Firm Diversity Index to Hire You – NOW…
giuffre-maxwell
gov.uscourts.nysd.447706.1100.1
13 pg
…
b) Shall be maintained in a safe and secure
manner;
c) Shall be reviewed and possessed by the
Defendant in hard copy solely in the presence of Defense
Counsel;
d) Shall be possessed in electronic format only
by Defense Counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.3
21 pg
…of which specifically identified by Bates
number Barden documents which Defendant had chosen to withhold based on attorney-client
issues. It is hard to understand how Ms. Giuffre’s motion could have been more precise with
regard to these communications…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.7
11 pg
…seven minutes of change.
4 MR. SCAROLA: Hard for me to believe that
5 but if the counter says what the counter says.
6 SPECIAL MASTER: The overtime got three
7 minutes, let's go.
8 REDIRECT EXAMINATION
9 BY…
giuffre-maxwell
gov.uscourts.nysd.447706.995.0
11 pg
…not properly ‘filed with the court’” are non-judicial
documents, and suggests that “hard copy documents that were submitted ex parte to Judge Sweet
and without notice to the defendant – such as those described by [Ms. Giuffre’s] supplemental
filing…