…Paula. Member of the Trilateral Commission and CFR. He Ghislaine Noelle Maxwell b 1961 is a British socialite and the youngest child of publisher Robert Maxwell. is Jean-Luc Brunel (JLB) JE co-conspirator-brother ARNAUD BRUNEL. In1976 Robert Maxwell…
…arises out of Defendant Maxwell’s defamatory statements against Plaintiff Giuffre. As described below, Giuffre was a victim of sexual trafficking and abuse while she was a minor child. Defendant Maxwell not only facilitated that sexual abuse but, most recently…
…s bedroom where Epstein would be on a massage table; Epstein would then sexually abuse the girl. This same pattern was repeated numerous times with numerous children. 4. “From between 1999 – 2007, Jeffrey Epstein sexually abused more than 30 minor …
…Deutsche Bank AG, 582 F. Supp. 2d 528 (S.D.N.Y. 2008) .................................................................................................... 9 Equal Emp't Opportunity Comm'n v. Nat'l Children's Ctr., Inc., 146 F.3d 1042 (D.C. Cir. 1998)...............................................................................…
…2d Cir. 2016)............................................................................................... passim Craig v. Harney, 331 U.S. 367 (1947) .................................................................................................................... 1 E.E.O.C. v. Nat’l Children's Ctr., Inc., 146 F.3d 1042 (D.…
…Defendant’s conduct with a minor was extreme and outrageous, going beyond all bounds of decency. Compl. ¶ 24. Defendant committed willful acts of child sexual abuse on Plaintiff. Compl. ¶ 25. These acts resulted in mental or sexual injury to Plaintiff…
…trafficking”). That characterization is not only offensive but also utterly irrelevant given that federal law does not recognize the concept of a child prostitute—there are only trafficking victims—because a child cannot legally consent to being exploited. Defense counsel…
…was then fifteen years old) to come to Epstein’s mansion in a fashion very similar to the manner in which Epstein and his other co-conspirators coerced dozens of other children (including Jane Doe #1 and Jane Doe #2)…
…defendant has no meaningful ties that would keep him in this country. The defendant has no known immediate family. He is not married and has no children. He has friends and associates worldwide, as demonstrated by his extensive international travel…
…he could look at or play with while in the bathtub. 67. These sexual encounters with Epstein, which of course were horribly abusive sexual assaults of a child, became more aggressive and escalated. For example, the second time it occurred…
…indictments and criminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take the steps necessary to protect our children from this very dangerous sexual predator.” (DE 407 at ¶ 118.) On July 7, 2008…
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