giuffre-maxwell
gov.uscourts.nysd.447706.1287.0
2 pg
…available until that motion, and the sealing/redaction request therein, is
resolved by the Court.
Document
# of Page Line(s) Identifier Redaction Requested
Transcript
1283 5 24-25 All text, as explained in Motion No text, as explained in Motion…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.1
8 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.447706.1202.2_1
10 pg
…results while AND will restrict result to only those which include all the terms.
Additionally, I want to clarify that I would like all of the metadata to be searched in
addition to the text of the documents. For example…
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.447706.17.1
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.447706.370.1
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.447706.29.0
2 pg
…at 8, 12.
1
In fact, the full text of each allegedly defamatory statement was set forth in the
Complaint. (Ex. A at 8).
Case 1:15-cv-07433-RWS Document 29 Filed 01/22/16 Page 2 of…
giuffre-maxwell
gov.uscourts.nysd.447706.320.0
11 pg
…Ordered
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.447706.1219.29
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.447706.279.0
8 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.447706.1332.1
42 pg
…ordered:
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.447706.1325.1
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.447706.1327.17
6 pg
…etc. Please confirm that you
have imaged her iPad as well as her phone in order to obtain the data from both (text messages, etc.).
One last thing - it occurred to me that in our discussion of terms that were…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 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.447706.1330.16
17 pg
…ordered:
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.447706.1296.12
29 pg
…Westwood
1
In her Motion to Compel, Defendant failed to comply with Local Rule 37.1 and only inserted
selected text from certain objections. Rule 37.1 requires: “upon any motion or application
involving discovery or disclosure requests or responses…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.2
13 pg
…results while AND will restrict result to only those which include all the terms.
Additionally, I want to clarify that I would like all of the metadata to be searched in
addition to the text of the documents. For example…
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.447706.1296.9
29 pg
…Westwood
1
In her Motion to Compel, Defendant failed to comply with Local Rule 37.1 and only inserted
selected text from certain objections. Rule 37.1 requires: “upon any motion or application
involving discovery or disclosure requests or responses…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.12
11 pg
…Ordered
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…
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