giuffre-maxwell
gov.uscourts.nysd.447706.1219.8
29 pg
…Cir. 2013) (“[t]he potential for privacy violations
occasioned by an unbridled, exploratory search of a hard drive is enormous”).
Because personal computers contain highly personal and sensitive material courts
generally require a heightened showing of good cause. See, e…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.28
24 pg
…checks, statements, receipts, summaries,
computer printouts, computer programs, text messages, e-mails, information kept in computer
hard drives, other computer drives of any kind, computer tape back-up, CD-ROM, other
computer disks of any kind, teletypes, telecopies, invoices, worksheets…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…receipts, summaries, computer printouts, computer programs, lext
messages, e-mails, information kept in computer hard drives, other computer drives of any kind,
computer tape back-up, CD-ROM. other computer disks of any kind, teletypes, lelecopies,
invoi(.:es, worksheets, printed…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.32
27 pg
…checks, statements, receipts, summaries,
computer printouts, computer programs, text messages, e-mails, information kept in computer
hard drives, other computer drives of any kind, computer tape back-up, CD-ROM, other
computer disks of any kind, teletypes, telecopies, invoices, worksheets…
giuffre-maxwell
gov.uscourts.nysd.447706.223.1
14 pg
…microfilms, checks, statements, receipts, summaries,
computer printouts, computer programs, text messages, e-maiIs, information kept in computer
hard drives, other computer drivcs of any kind, computer tape back-up, CD-ROM, other
computer disks of any kind, teletypes, teJecopics, invoices…
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…DOCUMENT REQUEST NO. 16
All computers, hard drives or copies thereof for all computers in operation between 1999 –
2002.
DOCUMENT REQUEST NO. 17
All documents relating to communications with you and Ross Gow from 2005 – present.
DOCUMENT REQUEST NO. 18
…
giuffre-maxwell
1320-32
27 pg
…checks, statements, receipts, summaries,
computer printouts, computer programs, text messages, e-mails, information kept in computer
hard drives, other computer drives of any kind, computer tape back-up, CD-ROM, other
computer disks of any kind, teletypes, telecopies, invoices, worksheets…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.29
24 pg
…checks, statements, receipts, summaries,
computer printouts, computer programs, text messages, e-mails, information kept in computer
hard drives, other computer drives of any kind, computer tape back-up, CD-ROM, other
computer disks of any kind, teletypes, telecopies, invoices, worksheets…
giuffre-maxwell
gov.uscourts.nysd.447706.555.0
21 pg
…or
intentionally destroyed evidence by burning, shredding, or wiping out computer hard drives."
I Id. at 469- 70 & n.48.
I ARGUMENT
I I. PLAINTIFF ADMITTED EACH ELEMENT OF INTENTIONAL SPOLIATION
Plaintiff admitted at her depositions to each factor required…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…12: Passports, Visas and Other Travel Documents ............................................ 6
E. Request 15-16: Financial Records to Support Her Claims ................................................. 7
F. Request 18: Driver’s License .......................................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.9
15 pg
…12: Passports, Visas and Other Travel Documents ............................................ 6
E. Request 15-16: Financial Records to Support Her Claims ................................................. 7
F. Request 18: Driver’s License .......................................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…Maxwell, I asked
15 her during her deposition: Was there a hard-copy book as well
16 as something on the computer or was there only electronic
17 information on the phone numbers?
18 This is after I handed her…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.2
23 pg
…lawyers at Boies Schiller therefore sought to turn the
lawsuit into a proxy prosecution of Epstein. Not surprisingly, discovery in the case was bitter,
hard-fought, and wide-ranging. It spanned more than a year and included large document
productions…
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.447706.968.0_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.447706.1069.0
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
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