…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…
…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…
…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…
…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…
…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…
…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…
…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 …
…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 …
…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…
…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…
…vs. CASE No. 502008CA028051XXXXMB AB JEFFREY EPSTEIN, Defendant. DEPOSITION OF • LOUELLA RABUYO …
…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 .......................................................................................…
…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 .......................................................................................…