giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…writing or record of every type and description that is or has been in Your
possession, custody or control, or of which You have knowledge, including but not limited to, e-
mails, text messages, instant messages, videotapes, photographs, notes, letters…
giuffre-maxwell
gov.uscourts.nysd.447706.991.1
48 pg
…Pleadings and Related Orders (“Case Management”)
9. Evidence and Motions filed for an Improper Purpose or Subject to a Motion to Strike or Exclude
(“Improper Purpose”)
Date Filed DE Category Docket Text
DECLARATION of Sigrid S.…
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…and every
disclosure, transfer or exchange of information whether orally or by document or otherwise,
face-to-face, by telephone, telecopies, e-mail, text, modem transmission, computer generated
message, mail, personal delivery or otherwise.
3. “Defendant” shall mean the defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.29
24 pg
…and every
disclosure, transfer or exchange of information whether orally or by document or otherwise,
face-to-face, by telephone, telecopies, e-mail, text, modem transmission, computer generated
message, mail, personal delivery or otherwise.
5. “Document” shall mean all written…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…account, cellphone number and cellphone
provider, social media account and login or screen name, text or instant messaging account name
and number, that You have used, applied for or been supplied between 1998 and the present.
Response to Interrogatory No…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…waiver under the law of the state where the disclosure
occurred.
8
Case 1:15-cv-07433-LAP Document 1320-18 Filed 01/03/24 Page 16 of 40
As is readily apparent from the text of the rule…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…defense, it is important to look at the actual text of that press statement::
Each time the story is re told it changes with new salacious details about public
figures and world leaders and now it is alleged by Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1196.0
32 pg
…the arguments section may be unsealed.
3 269. Reply and response to the motion for sanctions.
4 Unseal but redact the medical information, including the
5 treatment noted on page 2 in the text.
6 270. Declaration of Ms. Menninger…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.27
11 pg
…the
January 2015 statement. In the subject line is this text: “FW: URGENT – this is the
statement.” The “FW” is important—it is the abbreviation for “Forward,” indicating an
email has been forwarded by the sender, in this case Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.28
24 pg
…and every
disclosure, transfer or exchange of information whether orally or by document or otherwise,
face-to-face, by telephone, telecopies, e-mail, text, modem transmission, computer generated
message, mail, personal delivery or otherwise.
5. “Document” shall mean all written…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…and every
disclosure, transfer or exchange of i11formation whether ornlly or by document or otherwise,
face-to-face, by telephone, telecopies, e-mail, text, modem transmission, computer generated
message, mail, personal delivery or otherwise.
3. "Defendant" shall mean the ddendant…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.20
21 pg
…part .
Defendant is ordered to col l ect all ESI by imaging her
computers and collecting all email and text messages on any
devices in Defendant's possession or to which she has access
that Defendant used between th e…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…writing or record of every type and description that is or has been in Your
possession, custody or control, or of which You have knowledge, including but not
limited to, emails, text messages, instant messages, videotapes, photographs, notes,
letters, memoranda…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…account, cellphone number and cellphone
provider, social media account and login or screen name, text or instant messaging account name
and number, that You have used, applied for or been supplied between 1998 and the present.
Response to Interrogatory No…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…Inc., 435 U.S. 589, 598 (1978).
10 See notes 46–47 and accompanying text, post.
10
Case
Case
1:15-cv-07433-LAP
16-3945, Document
Document
315-2, 08/09/2019,
977-1 Filed2628211,
…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.32
27 pg
…and every
disclosure, transfer or exchange of information whether orally or by document or otherwise,
face-to-face, by telephone, telecopies, e-mail, text, modern transmission, computer generated
message, mail, personal delivery or otherwise.
3. "Document" shall mean all written…
giuffre-maxwell
gov.uscourts.nysd.447706.223.1
14 pg
…and every
disclosure, transfer or exchange of inJormatioll whether orally or by Document or othenvise,
taee-to-tace, by telephone, lelecopies, c-mail, text, modem transmission, computer generated
message, mail, personal delivery or otherwise.
3. "Plaintiff" in the above captioned…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…girls.
In my secret box, I also have old sim cards which still contain old text messages and telephone
numbers which I will have to send you next week once I have them. Hopefully Jens number will be
there and…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.9
21 pg
…part .
Defendant is ordered to collect all ESI by imaging her
computers and collecting all email and text messages on any
devices in Defendant's possession or to which she has access
that Defendant used between the period of 2002…
giuffre-maxwell
gov.uscourts.nysd.447706.78.0
30 pg
…GIUFFRE003714. This document does not
have an attachment. Therefore, no attachment to this document was produced. Indeed the text of
the chain itself establishes that Ms. Giuffre was unable to open the attachment. Nevertheless, to
avoid any issues, upon receiving…
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