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.447706.1219.8
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.447706.1320.31
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
1320-30
27 pg
…3 A Sydney is down here at the bottom. Cairns
4 is up here at the top.
5 Q Okay.
6 A It's probably a six-day drive.
7 Q Did you fly here through Sydney?
8 A No…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.30
27 pg
…3 A Sydney is down here at the bottom. Cairns
4 is up here at the top.
5 Q Okay.
6 A It's probably a six-day drive.
7 Q Did you fly here through Sydney?
8 A No…
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.447706.1295.14
6 pg
…Born in Brooklyn, he
had a middle-class upbringing: His father worked for the Parks Department, and his parents stressed
hard work and education.
Epstein was brilliant, skipping two grades and graduating Lafayette High School in 1969. He attended
'We…
giuffre-maxwell
gov.uscourts.nysd.447706.57.2
30 pg
…know-how, trade secrets and any other information concerning the Purpose and
also any information or analyses derived from, containing or reflecting such
information…
The recipient shall:
Keep the Confidential Information secret and confidential and not disclose any of…
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.447706.1295.3
7 pg
…ve given you what I know right
9 now. I'm sorry. This is very hard for me and very
10 frustrating to have to go over this. I don't -- I
11 don't recall all of the people. …
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.447706.1201.26
28 pg
…unequivocal recollection' of never being on a plane
with 'young women' he has a hard time explaining who the single-named females are who scatter
Pamela Anderson
the flight logs.
…