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.447706.1302.0
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.447706.1126.0
3 pg
…Maxwell’s April 2016 deposition transcript. She argues
that the District Court abused its discretion in ordering the unsealing of the deposition materials.
Specifically, she argues that there is a lower presumption of access to the deposition materials at
issue…
giuffre-maxwell
gov.uscourts.nysd.447706.149.0
9 pg
…wit, that Ms. Maxwell “assisted” and participated in
sexual abuse of the Plaintiff between 1999 and 2002.
Plaintiff does not claim that any sexual abuse occurred after 2002 or that she had any
contact with Ms. Maxwell after 2002. Indeed…
giuffre-maxwell
gov.uscourts.nysd.447706.408.0
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.
6. During the litigation, Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…any judicial
proceeding involving Ghislaine Maxwell or Virginia Giuffre, or in any proceeding relating to
Giuffre’s allegation that Jeffrey Epstein sexually abused her.
As a non-party to these proceedings, Doe lacks specific knowledge about the contents of
the…
giuffre-maxwell
gov.uscourts.nysd.447706.944.0
11 pg
…a series of salacious and
provocative allegations gratuitous to her defamation claim. She alleged she was the “victim of
sexual trafficking and abuse while she was a minor child” and that Ms. Maxwell “facilitated”
plaintiff’s sexual abuse and “wrongfully…
giuffre-maxwell
gov.uscourts.nysd.447706.851.0
158 pg
…I think, that
6 what was at issue was the truth or falsity of the plaintiff's
7 allegations concerning sexual abuse and the activities of the
8 defendant. I think that's my sense of my own opinion.
9…
giuffre-maxwell
gov.uscourts.nysd.447706.25.0
13 pg
…pled a defamation claim, and whether Ms. Maxwell was privileged to make her
statements—Plaintiff spends the bulk of her opposition repeating the same conclusory,
unsupported and false allegations that she was sexually abused by Ms. Maxwell. Plaintiff spends
the…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…effort
which were not and should not
have been relevant to Plaintiff’s false claim that she was sexually abused by Epstein as a minor.
The Second Circuit in Brown itself redacted from the summary judgment pleadings and exhibits
all…
giuffre-maxwell
gov.uscourts.nysd.447706.66.0_1
35 pg
…during that
7 time period, to up until now 2006, being abused in that
8 circumstance in Palm Beach. Then we have the arrest that
9 happens of Jeffrey Epstein in 2006.
10 Thereafter, my client in 2008 is -- I…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.17
13 pg
…of Confidential Materials. This
Court should issue an Order to Show Cause.
FACTUAL BACKGROUND
Ms. Giuffre sought to convert her defamation action into a lawsuit for child “sexual
abuse” and “sexual trafficking” of children. Toward that end, she made numerous…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.15
11 pg
…Jane Doe 43’s testimony clearly establishes that
her abuse continued within the ten (10) year statute of limitations period:
x She provided testimony demonstrating that Epstein’s abuse of Jane Doe 43 continued
during the ten (10) year window…
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
…when they have been accused of
12 misdeeds in the press, to respond, so long as they don't abuse
13 that privilege. And by abuse of privilege, that means
14 including numerous defamatory extraneous statements about the
15 person…
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.447706.1259.0
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.447706.1330.9
6 pg
…Further, the idea that Ms Maxwell would contemplate an arrangement with someone who
abused drugs and alcohol contemporaneously and who was living with her fiancé beggars belief.
No document has ever been contemplated, created nor lawyer nor other approached to…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.39
36 pg
…during that
7 time period, to up until now 2006, being abused in that
8 circumstance in Palm Beach. Then we have the arrest that
9 happens of Jeffrey Epstein in 2006.
10 Thereafter, my client in 2008 is -- I…
giuffre-maxwell
gov.uscourts.nysd.447706.96.0
15 pg
… Documents Evidencing Communications and Interactions With
Co-Conspirators.............................................................................................................3
B. Documents Concerning Sexual Abuse And Trafficking Of Females............................4
III. ARGUMENT – FORE…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…that she,
Giuffre, had been interviewed by the Federal Bureau of
Investigation ("FBI") in 2011, and that she had discussed
Maxwell's involvement in the described sexual abuse. Maxwell
issued a statement denying this account on March 9, 2011.
2…
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