Giuffre v. Maxwell - Unsealed Documents Batch 7

January 8, 2024 VIA ECF The Honorable Loretta A. Preska District Court Judge United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Giuffre v. Maxwell, Case No. 15-cv-7433-LAP Dear Judge Preska, Pursuant to the Court’s December 18, 2023, unsealing order, and following conferral with Defendant, Plaintiff files this set of documents ordered unsealed. The filing of these documents ordered unsealed will be done on a rolling basis until completed. This filing also excludes documents pertaining to Does 105 (see December 28, 2023, Email Correspondence with Chambers), 107, and 110 (see ECF No. 1319), while the Court’s review of those documents is ongoing. Respectfully, /s/ Sigrid S. McCawley Sigrid S. McCawley cc: Counsel of Record (via ECF) Case 1:15-cv-07433-LAP Document 1332 Filed 01/08/24 Page 1 of 1 COMPOSITE EXHIBIT 1 (FILE UNDER SEAL) Case 1:15-cv-07433-LAP Document 1332-1 Filed 01/08/24 Page 1 of 42 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S MOTION TO COMPEL DATA FROM DEFENDANT’S UNDISCLOSED EMAIL ACCOUNT AND FOR AN ADVERSE INFERENCE INSTRUCTION Plaintiff, Virginia Giuffre, by and through her undersigned counsel, files this Motion to Compel Data from Defendant’s Undisclosed Email Account and for An Adverse Inference Instruction regarding the data from that account, and states as follows. Defendant has not disclosed, nor produced data from, the email account she used while abusing Ms. Giuffre from 2000-2002 in violation of this Court’s Order [DE 352]. Ms. Giuffre hereby moves to compel Defendant to produce this data, and requests that this Court enter an adverse inference jury instruction for this willful violation of this Court’s orders. I. BACKGROUND The earliest-dated email Defendan