giuffre-maxwell
gov.uscourts.nysd.447706.988.0_2
6 pg
…a dozen boxes of material, presumably all of the deposition transcripts,” but then
speculates that the transcripts were “unread” and asserts that “[t]he parties do not know whether
Judge Sweet ever reviewed any of the deposition designations, counter-designations…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.25
11 pg
…production on February 8, 2016. All documents identified as responsive were reviewed by
counsel and either produced or placed on a privilege log. The First Responses were the subject
of litigation in March and April 2016. This Court limited the…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…supplement to her motion for an adverse inference
instruction based on new information, follows. Most notably, Defendant claims to have run
search terms and reviewed over 10,000 documents, but, remarkably, claims that not a single
document - not one - is…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.12
11 pg
…production on February 8, 2016. All documents identified as responsive were reviewed by
counsel and either produced or placed on a privilege log. The First Responses were the subject
of litigation in March and April 2016. This Court limited the…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.1_1
11 pg
…production on February 8, 2016. All documents identified as responsive were reviewed by
counsel and either produced or placed on a privilege log. The First Responses were the subject
of litigation in March and April 2016. This Court limited the…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.12
15 pg
…4 patient packet and showed up for a new patient
5 appointment for a particular reason. I reviewed it.
6
7
Jane Doe 2
8 Q Do you know where that new patient packet
9 is now?
10 A It…
giuffre-maxwell
gov.uscourts.nysd.447706.111.2
5 pg
…parties have confirmed that Plaintiff’s deposition has yet to be taken
in light of this outstanding discovery dispute.
Having reviewed and considered Defendant’s motion to compel [DE 40] and Plaintiff’s
opposition [DE 41] the Court is GRANTING…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.31
13 pg
…RFP No. 1 seeks documents Mr. Pagliuca allegedly ‘reviewed and/or relied upon’ in
allegedly making statements stating that Plaintiff previously made false accusations of sexual
assault.” (Br. at 5). (Emphasis original).
How Defendant purports to distinguish between the actual…
giuffre-maxwell
gov.uscourts.nysd.447706.363.9
5 pg
…conducted, under my
supervision, by former senior federal law enforcement officials. We interviewed many
witnesses and reviewed thousands of pages of documentary evidence. Our investigation
found no evidence to support the accusations of sexual misconduct against Professor
Dershowitz. In fact…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.0_2
65 pg
…production on February 8, 2016. All documents identified as responsive were reviewed by
counsel and either produced or placed on a privilege log. The First Responses were the subject
of litigation in March and April 2016. This Court limited the…
giuffre-maxwell
gov.uscourts.nysd.447706.320.0
11 pg
…production on February 8, 2016. All documents identified as responsive were reviewed by
counsel and either produced or placed on a privilege log. The First Responses were the subject
of litigation in March and April 2016. This Court limited the…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.11
13 pg
…RFP No. 1 seeks documents Mr. Pagliuca allegedly ‘reviewed and/or relied upon’ in
allegedly making statements stating that Plaintiff previously made false accusations of sexual
assault.” (Br. at 5). (Emphasis original).
How Defendant purports to distinguish between the actual…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.18
11 pg
…claims for the purpose of getting paid hundreds of thousands of dollars by the media for
publicizing her allegations and identifying well know public figures whose names she has seen documents that she
reviewed or other stories she had read.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1100.1
13 pg
…
b) Shall be maintained in a safe and secure
manner;
c) Shall be reviewed and possessed by the
Defendant in hard copy solely in the presence of Defense
Counsel;
d) Shall be possessed in electronic format only
by Defense Counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…she had run
comprehensive search terms, thoroughly reviewed her records and previously produced all
responsive documents in her possession.7
The second factor, that “the party that failed to timely produce the evidence had ‘a
culpable state of mind’” is…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.17_1
16 pg
…2, 2009). First, as reviewed in detail on a witness-by-witness basis
above, the discove1y sought is not duplicative. The proposed deponents include the individual
who assisted in making the defainatory statement, women Defendant Maxwell hired to recrnit
girls…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
45 pg
…any formal training in providing massages.
I showed a photo line up in which Nada Marcinkova was placed in
position six. She reviewed the six photographs and immediately
identified Nada Marcinkova as the person with whom she had
intercourse. Additionally…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.18_2
15 pg
…2, 2009). First, as reviewed in detail on a witness-by-witness basis
above, the discove1y sought is not duplicative. The proposed deponents include the individual
who assisted in making the defamatory statement, women Defendant Maxwell hired to recrnit
girls…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.16_2
15 pg
…2, 2009). First, as reviewed in detail on a witness-by-witness basis
above, the discove1y sought is not duplicative. The proposed deponents include the individual
who assisted in making the defamato1y statement, women Defendant Maxwell hired to recrnit
girls…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.16
10 pg
…remember how old you were when you met Jeffrey Epstein?
A. Sixteen or 17.
Q. Okay. And have you reviewed –
A. I may have been 15. I don't recall. I apologize.
Q. If you told the police officer 16…