…Civ. P., of the Rugged Thunderbolt External Hard Drive (“Rugged TBT Drive”) Plaintiff asserts that he purchased and which is at the core of this putative consumer class action. See DE 40. The parties have confirmed that Plaintiff’s deposition…
…Defendant’s devices attempted to recover Defendant’s deleted email and other documents, or attempted to identify if and when a hard drive was wiped. In these circumstances, the Court should allow an independent forensic expert review the computer and…
…Defendant’s devices attempted to recover Defendant’s deleted email and other documents, or attempted to identify if and when a hard drive was wiped. In these circumstances, the Court should allow an independent forensic expert review the computer and…
…Defendant’s devices attempted to recover Defendant’s deleted email and other documents, or attempted to identify if and when a hard drive was wiped. In these circumstances, the Court should allow an independent forensic expert review the computer and…
…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…
…Maxwell has no reason to believe that the account exists. Conclusion WHEREFORE, counsel for Ms. Maxwell through a certified forensic examiner has: a. imaged the hard-drives of Ms. Maxwell’s devices; b. imaged the servers containing emails from Ms…
…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…
…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…
…or intentionally destroyed evidence by burning, shredding, or wiping out computer hard drives.” Id. at 469–70 & n.48. ARGUMENT I. PLAINTIFF ADMITTED EACH ELEMENT OF INTENTIONAL SPOLIATION Plaintiff admitted at her depositions to each factor required for a finding…
…or intentionally destroying evidence by burning, shredding, or wiping out computer hard drives.”) (emphasis supplied). The motivation for the action is irrelevant. The purposeful nature and manner of the destruction is all that matters. 5 Because the act of…
…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…
…Maxwell has no reason to believe that the account exists. Conclusion WHEREFORE, counsel for Ms. Maxwell through a certified forensic examiner has: a. imaged the hard-drives of Ms. Maxwell’s devices; b. imaged the servers containing emails from Ms…
…or intentionally destroying evidence by burning, shredding, or wiping out computer hard drives.”) (emphasis supplied). The motivation for the action is irrelevant. The purposeful nature and manner of the destruction is all that matters. 5 Because the act of…
…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…
…ROBERT CRITTON, ESQ. 12 JANE DOE NO. 102, Case No: 09-CV-80656 12 515 North Flagler Drive 13 Plaintiff, SUite 400 14 Vs 13 We…
…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…
…were responsive to the Defendant’s subpoena. 3 Defendant also requested a copy of the CD of photographs that non-party Ms. Ransome already produced in hard copy. A copy of said CD has been made and sent to Defendant. …
…were responsive to the Defendant's subpoena . 3 Defendant also requested a copy of the CD of photographs that non-pai1y Ms. Ransome aheady produced in hard copy. A copy of said CD has been made and sent to Defendant. …
…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…
…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…