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.447706.1196.0
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.447706.1330.16
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.447706.1296.9
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.447706.1331.35
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.447706.1332.7
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.447706.1327.19
21 pg
…would have the Court believe that Defendant and her friend
never communicated about Ms. Giuffre’s testimony. There are no emails; no text messages
-
produced.
iii.
:
Q. Do you remember speaking with a female by the name of ?
…
giuffre-maxwell
gov.uscourts.nysd.447706.230.0
19 pg
…email 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.” Menninger Decl., Ex…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…(2025), https://www.congress.gov/bill/119th-
congress/house-bill/4405/text.
6
VIRGINIA ROBERTS GIUFFRE, NOBODY’S GIRL: A MEMOIR OF SURVIVING ABUSE AND FIGHTING FOR JUSTICE
(2025)
3
Case 1:15-cv-07433-LAP Document 1354 Filed…
giuffre-maxwell
gov.uscourts.nysd.447706.1334.1
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.447706.872.0
76 pg
…t [Giuffre] ha s alleged .
Id.
Maxwell argues that th e " con text " of the ent i re
statement "tested against the understanding of the average
reader " should be that of a pr ess rele ase as a whole being…
giuffre-maxwell
gov.uscourts.nysd.447706.983.0
24 pg
…2 And, Mr. Lewin, do not write those teeny, little
3 footnotes. The rules say 12 point-type text in footnotes. I
4 can't read those teeny, little footnotes.
5 MR. PAGLIUCA: And, your Honor, that is per category…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…each
document was an abuse of court records, merely stating that the documents are “textbook examples
of materials that should not be submitted to courts because of their potential for abuse.” Id. Filing
excerpts from deposition transcripts or summaries of…
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