DataSet-11
EFTA02261286
4 pg
…receipt to the recipient's
correct email address. Disney is not responsible for any loss or inconvenience caused by
computer error or from the failure of the gift receipt to reach the recipient, nor for the
unauthorized duplication or use…
DataSet-9
EFTA00597642
8 pg
…Request for a Hearing on
Appropriate Remedies (DE 48) (the victims' "summary judgment motion") along with a Motion
to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts
(DE 49).
On September 26…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.1
8 pg
…Plaintiff, Virginia Giuffre, hereby submits this Motion for an Adverse Inference
Instruction to the jury for failure to comply with a Court Order pursuant to Rule 37(b); for failure
to preserve electronically stored information pursuant to Rule 37(e)…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.5_2
30 pg
…Defendant.
________________________________/
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION FOR
DEFENDANT’S RULE 37(b) &(c) SANCTIONS FOR FAILURE TO COMPLY WITH
COURT ORDER AND FAILURE TO COMPLY WITH RULE 26(a)
Case 1:15-cv-07433-LAP…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.12_3
30 pg
…Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S CORRECTED1 RESPONSE IN OPPOSITION TO DEFENDANT’S
MOTION FOR DEFENDANT’S RULE 37(b) &(c) SANCTIONS FOR FAILURE TO
COMPLY WITH COURT ORDER AND FAILURE TO COMPLY WITH RULE 26(a)
1
Due to inadvertence…
giuffre-maxwell
gov.uscourts.nysd.447706.279.0
8 pg
…Plaintiff, Virginia Giuffre, hereby submits this Motion for an Adverse Inference
Instruction to the jury for failure to comply with a Court Order pursuant to Rule 37(b); for failure
to preserve electronically stored information pursuant to Rule 37(e)…
…Um, and let's
[00:00:16] say this daughter has some uh some kind
[00:00:19] of condition or organ failure or
[00:00:21] something where she needs a body part
[00:00:24] from her mom…
podesta-emails
Email
…Lake
Forest, CA. Below are the notes from our call.
Big Highlights
- McCain cites failure of his 1st marriage as greatest personal moral
failure
- Says to him, faith means 'i'm saved and forgiven'
- w/r/t taxes, jokes that…
dnc-emails
Email
…in his speech today. All but said that people involved in foreign policy over the last 15 years were worthless because they've been involved in failure.
Called on Cruz and Kasich to get out multiple times. Said he would…
dnc-emails
Email
…4T5rto3SfG0s0jr3iAVb3NCn9Q73kiph
PSwHuRxcm+hWNszjJg3/W+Fr8fdXAh5i0JzMNscuFAQNHgfhLigenq+BpCnZzXya
01kqX24AdoSIbH++vvgE0Bjj6mzuRrH5VJ1Qg9nQ+yMjBWZADljtp3CARUbNkiIg
tUJ8IJHCGVwXZBqY4qeJc3h/RiwWM2UIFfBZ+E06QPznmVLSkwvvop3zkr4eYNez
cIKUju8vRdW6sxaaxC/GECDlP0Wo6lH0uChpE3NJ1daoXIeymajmYxNt+drz7+pd
jMqjDtNA2rgUrjptUgJK8ZLdOQ4WCrPY5pP9ZXAO7+mK7S3u9CTywSJm…
DataSet-9
EFTA00164459
1 pg
…NY. Epstein was discovered with I fabricated noose around his neck in what was an apparent suicide.
Preliminary investigation revealed I series of protocol failures by MCC personnel, as well as technical failures/deficiencies
within the MCC at the time…
DataSet-9
EFTA00130149
494 pg
…NY. EPSTEIN was discovered with a fabricated noose around
his neck in what was an apparent suicide.
Preliminary investigation revealed a series of protocol failures by
MCC personnel, as well as technical failures/deficiencies within the MCC
at the time…
DataSet-9
EFTA00148081
41 pg
…Discusses Alerting FBI About Father's Alleged Role In Capitol Siege.
• Acting Capitol Police Chief Apologizes For January 6 Failures.
• Biden Administration Overhauling Government Approach To Domestic Extremism.
COUNTER-TERRORISM
• Texas Man Pleads Guilty To Planning Terror Attack.
• Columnist: Church…
DataSet-9
EFTA00164376
1 pg
…NY. Epstein was discovered with a fabricated noose around his neck in what was an apparent suicide.
Preliminary investigation revealed a series of protocol failures by MCC personnel, as well as technical failures/deficiencies
within the MCC at the time…
dnc-emails
Email
…Republican Party shot/chaser blast
* Today: State party call on Trump narrative at 12pm ET
* Today: Flint release on Republican failures prefacing POTUS visit
* Today: SCOTUS release on Republican Senators waiting for Trump
* Today: Trump as GOP nominee article round…
dnc-emails
Email
…Republican Party shot/chaser blast
* Today: State party call on Trump narrative at 12pm ET
* Today: Flint release on Republican failures prefacing POTUS visit
* Today: SCOTUS release on Republican Senators waiting for Trump
* Today: Trump as GOP nominee article round…
DataSet-9
EFTA00381056
2 pg
…trip cost is charged for any cancellation less than the specified hours for a reserved vehicle prior to a scheduled pickup time. Tristar is not
responsible for failure to comply with this policy due to client incidents or missed, cancelled…
DataSet-9
EFTA00605641
3 pg
…most patients (> 75%) still do not achieve glucose targets, which increase the
incidence of long-term devastating complications such as blindness, kidney failure, heart disease
and lower extremity amputations. Hypoglycemia (dangerously low glucose levels) is also a fact
of…
DataSet-9
EFTA00105466
2 pg
…it had
preserved video from the wrong tier inside the facility. The failure to preserve the correct video was the result of
an error in MCC's computer systems, which incorrectly identified Tartaglione's cell as being on a different…
DataSet-10
EFTA01365477
1 pg
…successor has been appointed within 30 days after such resignation, the Investment Manager (on
behalf of the Issuer) shall promptly notify the Trustee of such failure in writing.
(b) On or before May 31 of each year, commencing in 2012…