giuffre-maxwell
gov.uscourts.nysd.447706.733.0
3 pg
…Virginia L. Giuffre,
Plaintiff,
Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
____________________________/
DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF PLAINTIFF’S
RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION IN LIMINE TO EXCLUDE
VICTIM
giuffre-maxwell
gov.uscourts.nysd.447706.1328.22
22 pg
…after
seHvice
1 'I 9.071 (2)(d) Surveillance t niques, procedures, an (2)(h)(1) Identity of victim of sexual battery, lewd and
inventory of law enforcement resources, policies or ascivious offense upon a person less than 16 years…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…29/20 Page 6 of 161
Socialite Ghislaine Maxwell 'groped a 16-year-old girl
during a naked massage,' victims' lawyer says
dailymail.co.uk/news/article-8163681/Socialite-Ghislaine-Maxwell-groped-16-year-old-girl-naked-massage-victims-
lawyer…
giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
…The Intervenors’ requests to unseal should be denied.
A. Intervenors’ First Proposition of Law: For minor victims of sexual abuse, “redactions
should be applied sparingly to shield only information that would identify those who
have not already been publicly identified…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…and JANE DOE #2
v.
UNITED STATES
__________________________/
JANE DOE #3 AND JANE DOE #4’S MOTION PURSUANT TO RULE 21 FOR
JOINDER IN ACTION
COME NOW Jane Doe #3 and Jane Doe #4 (also referred to as “the new victims”)…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.21
19 pg
…days after
service
C 11 ~W71 (2)(d) Surveillance t niques, procedures, an (2)(h)(1) Identity of victim of sexual battery, lewd and
inventory of law enforcement resources, policies or ascivious offense upon a person less than 16 years…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.5
3 pg
…1 is a true and correct copy of September 2,
2008, Victim Notification Letter (GIUFFRE001203-GIUFFRE001205).
4.
-
Attached hereto as Sealed Exhibit 2 is a true and correct copy of Excerpts of
January 16 2016, Deposition of Virg…
giuffre-maxwell
gov.uscourts.nysd.447706.41.5
18 pg
…ORDER
Upon a showing of good cause in support of the entry of a protective order to protect
the discovery and dissemination of confidential information, including sensitive personal
information relating to a victim of sexual abuse, copyright or trade secrets…
giuffre-maxwell
gov.uscourts.nysd.447706.185.4
10 pg
…concludes that they
should be denied.
I. Background
This is an action by two unnamed petitioners, Jane Doe 1 and Jane Doe 2, seeking to
prosecute a claim under the Crime Victims’ Rights Act (CVRA), 18 U.S.C. § 3771…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.36_1
35 pg
…any) from FBI
records. You need to include as many details as possible so they can focus and narrow the search.
Explain that you are looking for information related to your recovery as a victim of . The
process may take…
giuffre-maxwell
gov.uscourts.nysd.447706.562.1
13 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…and JANE DOE #2
v.
UNITED STATES
__________________________/
JANE DOE #3 AND JANE DOE #4’S MOTION PURSUANT TO RULE 21 FOR
JOINDER IN ACTION
COME NOW Jane Doe #3 and Jane Doe #4 (also referred to as “the new victims”)…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.14
6 pg
…known as "Orgy lsland," have included Bill Cllnton, Prince Andrew and Stephen Hawking.
According to a 2011 court fillng by alleged Epstein victim Virginia Roberts Giuffre, she saw Clinton and Prince Andrew on the island but
never saw the former…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…1 and Jane Doe 2, as well as movants Jane Doe
No. 3 and Jane Doe No. 4 (“the victims” 1), to respond in opposition to Mr. Dershowitz’s motio n
for limited intervention (DE 282). Dershowitz moves to intervene…
giuffre-maxwell
gov.uscourts.nysd.447706.385.0
2 pg
…representing
. Although Ms. Giuffre is not a
, central to that action are her allegations that she was the
victim of “sexual trafficking.”
4. Based on my knowledge of the …
giuffre-maxwell
1320-9
10 pg
…and JANE DOE #2
v.
UNITED STATES
__________________________/
JANE DOE #3 AND JANE DOE #4’S MOTION PURSUANT TO RULE 21 FOR
JOINDER IN ACTION
COME NOW Jane Doe #3 and Jane Doe #4 (also referred to as “the new victims”)…
giuffre-maxwell
gov.uscourts.nysd.447706.773.4
5 pg
…is on a list of witnesses for trial in a Palm Beach
lawsuit that pits billionaire pedophile Jeffrey Epstein against a Fort
Lauderdale attorney who represents Epstein’s victims.
The case appears bound for trial this summer following a Feb…
giuffre-maxwell
gov.uscourts.nysd.447706.26.1
26 pg
…Courts
Substance or procedure; determinativeness
Federal courts sitting in diversity apply state
Synopsis
substantive law and federal procedur…
giuffre-maxwell
gov.uscourts.nysd.447706.1.0
12 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.24.1
13 pg
…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…
Comments