giuffre-maxwell
gov.uscourts.nysd.447706.1320.8
12 pg
…Service.
The three persons to be subpoenaed – Jeffrey Epstein, Sarah Kellen and Nadia Marcinkova –
were each involved in the sexual abuse and sexual trafficking at issue in this case. It appears that
all three of them have evaded attempts to…
giuffre-maxwell
1320-8
12 pg
…Service.
The three persons to be subpoenaed – Jeffrey Epstein, Sarah Kellen and Nadia Marcinkova –
were each involved in the sexual abuse and sexual trafficking at issue in this case. It appears that
all three of them have evaded attempts to…
giuffre-maxwell
gov.uscourts.nysd.447706.542.8
4 pg
…Revenue Code, or the corresponding section of any future federal tax
code. The corporation is organized to provide assistance to victims of sexual abuse as well as victims of human trafficking.
Upon the dissolution of Victims Refuse Silence, Inc., assets…
giuffre-maxwell
gov.uscourts.nysd.447706.160.0
12 pg
…Service.
The three persons to be subpoenaed – Jeffrey Epstein, Sarah Kellen and Nadia Marcinkova –
were each involved in the sexual abuse and sexual trafficking at issue in this case. It appears that
all three of them have evaded attempts to…
giuffre-maxwell
gov.uscourts.nysd.447706.712.0
11 pg
…e.g., Plaintiff’s Statement of Undisputed Facts in Response to Defendant’s Motion for
Summary Judgment at 4-27 (recounting details of Epstein’s and Defendant’s sex trafficking and sex
abuse conspiracy); see also Plaintiff Giuffre’s Reply…
giuffre-maxwell
gov.uscourts.nysd.447706.686.0
17 pg
…Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF MS. GIUFFRE’S MEMORANDUM OF LAW IN
SUPPORT OF HER MOTION IN LIMINE TO PRESENT
ALL EVIDENCE OF DEFENDANT’S INVOLVEMENT IN
EPSTEIN SEXUAL ABUSE AND SEX TRAFFICKING
…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…Docket Entries. ............. 8
A. “Personal” Information in Maxwell’s Deposition Transcript Does Not Warrant
Continued Sealing. .............................................................................................................. 9
B. The Potential for “Media Abuse” Does Not Warrant C…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…used his vast wealth and property holdings and a deliberately opaque web of
corporations and companies to transport young women and girls to his privately-owned islands
where they were held captive and subject to severe and extensive sexual abuse…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.23
9 pg
…Ms. Giuffre has alleged that Defendant defamed her when she
called her a liar after Ms. Giuffre spoke out about being a child victim of sex abuse at the hands of
Defendant and Defendant’s long-time boyfriend, convicted pedophile…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…As the
Court will recall, in court pleadings filed December 30, 2014, Ms. Giuffre initially publicly
alleged Defendant had sexually abused her. On September 21, 2015, Ms. Giuffre filed her
lawsuit against Defendant here in the Southern District of New…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…As the
Court will recall, in court pleadings filed December 30, 2014, Ms. Giuffre initially publicly
alleged Defendant had sexually abused her. On September 21, 2015, Ms. Giuffre filed her
lawsuit against Defendant here in the Southern District of New…
giuffre-maxwell
gov.uscourts.nysd.447706.604.0
11 pg
…Giuffre or publishing any of the intimate facts
involving her victimization (in fact, he would not ordinarily oppose her redacting the details of
her abuse – however, he is not in a position to stipulate to this Court suspending the First…
giuffre-maxwell
gov.uscourts.nysd.447706.492.0
9 pg
…Ms. Giuffre has alleged that Defendant defamed her when she
called her a liar after Ms. Giuffre spoke out about being a child victim of sex abuse at the hands of
Defendant and Defendant’s long-time boyfriend, convicted pedophile…
giuffre-maxwell
gov.uscourts.nysd.447706.102.0
9 pg
…turning on whether Defendant defamed Ms. Giuffre by calling her a liar when
Ms. Giuffre reported the sexual abuse she suffered as a minor child. Ms. Giuffre has sought to
move the case along towards the projected trial date in…
giuffre-maxwell
gov.uscourts.nysd.447706.231.0
23 pg
…actual
computation of her damages, or any documentation supporting those claims.
1
Case 1:15-cv-07433-LAP Document 231 Filed 06/20/16 Page 4 of 23
These discovery abuses cannot be condoned. All of this information is…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.1
8 pg
…Cir.1972)).
“An adverse inference serves the remedial purpose “of restoring the prejudiced party to the
same position he would have been in absent the wrongful destruction of [or willful refusal to
produce] evidence by the opposing party.” Chevron Corp…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…ii. Eva Dubin
Defendant also appears to be claiming that she had not had even a single communications
with Eva Dubin, Defendant’s long-time friend whose husband was implicated in sexual abuse by
Ms. Giuffre’s deposition testimony. Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…00490 (S.D.N.Y. filed July 2, 2019). Following his death a month later,1 twenty-three women
testified that Jeffrey Epstein abused and trafficked them.2 Previously, “[o]n June 30, 2008, Epstein
pleaded guilty to Florida state…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.19
21 pg
…ii. Eva Dubin
Defendant also appears to be claiming that she had not had even a single communications
with Eva Dubin, Defendant’s long-time friend whose husband was implicated in sexual abuse by
Ms. Giuffre’s deposition testimony. Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.16
30 pg
…21
iii
Case 1:15-cv-07433-LAP Document 1256-16 Filed 05/03/22 Page 5 of 30
INTRODUCTION
As more and more witnesses come forward testifying about Defendant’s involvement in
the sexual abuse of young girls…