giuffre-maxwell
gov.uscourts.nysd.447706.1302.0
3 pg
…of “any and all documents” filed in Giuffre v. Maxwell that “identify the men who abused
the girls trafficked by Jeffrey Epstein and Defendant Maxwell.” Appellant’s App’x at 260. The
District Court denied TGP’s motion to intervene…
giuffre-maxwell
gov.uscourts.nysd.447706.1305.0
4 pg
…unsealing certain
litigation materials that identify her. She argues that the District Court abused its discretion in
unsealing those materials principally by giving undue weight to the effect of prior disclosures of Doe
171’s identity, failing to “include a …
giuffre-maxwell
gov.uscourts.nysd.447706.1304.0
3 pg
…Doe 107 argues that the District Court abused its discretion by
“ignor[ing]” her assertion that identifying her “could place her in mortal danger in her culturally
conservative home country,” in which “‘honor’ killings are a real risk,” and “instead…
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.447706.1.0
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.1
13 pg
…co-counsel Bradley J. Edwards, I have been pursuing a federal case pro bono on behalf of two
young women who were sexually abused as underage girls by Dershowitz’s close personal friend
– Jeffrey Epstein.
5. On July 7, 2008…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.45
13 pg
…co-counsel Bradley J. Edwards, I have been pursuing a federal case pro bono on behalf of two
young women who were sexually abused as underage girls by Dershowitz’s close personal friend
– Jeffrey Epstein.
5. On July 7, 2008…
giuffre-maxwell
gov.uscourts.nysd.447706.1303.0
3 pg
…Doe 107 argues that the District Court abused its discretion by
“ignor[ing]” her assertion that identifying her “could place her in mortal danger in her culturally
conservative home country,” in which “‘honor’ killings are a real risk,” and “instead…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.22
17 pg
…As the Court is aware, this defamation case involves Ms. Giuffre’s assertions that she and
other females were recruited by Defendant to be sexually abused by Jeffrey Epstein under the
guise of being “massage therapists.” See Complaint, DE1, at …
giuffre-maxwell
gov.uscourts.nysd.447706.1074.0
18 pg
…P. 12(f).
Petitioners’ Rule 21 Motion consists of relatively little argumentation regarding why the
Court should permit them to join in this action: they argue that (1) they were sexually abused by
1
The Court notes that, regardless of…
giuffre-maxwell
gov.uscourts.nysd.447706.1067.0
10 pg
…public at trial, and any party’s
reliance on the Protective Order to prevent all sensitive information from becoming public is
unfounded.
B. Prevention of the Abuse of Court Records and Files
Ms. Maxwell again mischaracterizes Brown v. Maxwell in…
giuffre-maxwell
gov.uscourts.nysd.447706.185.4
10 pg
…P. 12(f).
Petitioners’ Rule 21 Motion consists of relatively little argumentation regarding why the
Court should permit them to join in this action: they argue that (1) they were sexually abused by
1
The Court notes that, regardless of…
giuffre-maxwell
gov.uscourts.nysd.447706.1028.0
5 pg
…he might
consider benign and insignificant. However, Doe #100 likely has significant privacy
and other interests in the unsealing of materials in which a person alleges he sexually
abused a minor. In the second disclosure, he has a weighty “countervailing…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.8
29 pg
…Pagliuca “stated that (1) Plaintiff made false allegations concerning her sexual assault;
(2) she made them in roughly the same time frame that Plaintiff was abused by Jeffrey Epstein;
(3) that the allegations were made against a number of individuals…
giuffre-maxwell
gov.uscourts.nysd.447706.542.5
11 pg
…Petitioners' Rule 21 Motion consists of relatively little argumentation regarding why the
Court should permit them to join in this action. they argue that ( 1) they were sexually abused by
The Court notes that, regardless of which motion it considers…
giuffre-maxwell
gov.uscourts.nysd.447706.551.0
17 pg
…government
officials, media moguls and high profile business people. Cernovich Media is an organization
whose mission is to use and promote investigative journalism as a tool to expose corruption and
abuse of public power by promoting transparency, accountability, and public…
giuffre-maxwell
gov.uscourts.nysd.447706.363.4
11 pg
…P. 12(f).
Petitioners’ Rule 21 Motion consists of relatively little argumentation regarding why the
Court should permit them to join in this action: they argue that (1) they were sexually abused by
1
The Court notes that, regardless of…
giuffre-maxwell
gov.uscourts.nysd.447706.54.0
11 pg
…criminal conduct against Giuffre or
anyone else. No civil complaint has ever been lodged against Ms. Maxwell for sexual
misconduct nor abuse nor has she settled privately any private claims for such. Indeed, no other
person has ever made any…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.5
11 pg
…P. 12(f).
Petitioners’ Rule 21 Motion consists of relatively little argumentation regarding why the
Court should permit them to join in this action: they argue that (1) they were sexually abused by
1
The Court notes that, regardless of…