giuffre-maxwell
gov.uscourts.nysd.447706.1327.2
13 pg
…includes any cloud storage accounts. Please confirm that you have imaged Ms.
Maxwell's hard drives and other devices.
Once you have gathered that data onto a platform (such as Summation or its functional
equivalent), please run the below search…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.13
13 pg
…includes any cloud storage accounts. Please confirm that you have imaged Ms.
Maxwell's hard drives and other devices.
Once you have gathered that data onto a platform (such as Summation or its functional
equivalent), please run the below search…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…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…
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.447706.1327.19
21 pg
…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…
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.447706.515.0
12 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.5
12 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.7
9 pg
…ESQ.
12 JANE DOE NO . 102, Case No: 09 -CV-80656 12 515 North Flagler Drive
13 Pla intiff, Suite 400
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.17
6 pg
…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…
giuffre-maxwell
1320-7
9 pg
…ESQ.
12 JANE DOE NO . 102, Case No: 09 -CV-80656 12 515 North Flagler Drive
13 Pla intiff, Suite 400
…
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.447706.1328.22
22 pg
…BUNNER HOW THEY WERE POSITIONED AND HE SAID IT WAS HARD TO
DESCRIBE . 'HE SAID THAT KEVIN WAS IN THE DRIVER'S SEAT AND THAT · HE WAS
IN THE PASSENGE,R SEAT AND THAT SHE WAS IN THE MIDDLE…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.7
29 pg
…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.
…
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.447706.1334.1
29 pg
…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.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.19
22 pg
…but yes, it's in
21 my handwriting and it's got all of my information on
22 it.
23 Q Okay. And on line -- box 23 it's got your
24 driver's license checked off, right?
25 A…
giuffre-maxwell
1320-19
22 pg
…but yes, it's in
21 my handwriting and it's got all of my information on
22 it.
23 Q Okay. And on line -- box 23 it's got your
24 driver's license checked off, right?
25 A…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.13_1
23 pg
…but yes, it's in
21 my handwriting and it's got all of my information on
22 it.
23 Q Okay. And on line -- box 23 it's got your
24 driver's license checked off, right?
25 A…
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…