giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…allegedly sexually assaulted 16-year-old Annie
Farmer
It reportedly happened at paedophile Epstein's 7,500-acre New Mexico
ranch
A lawyer for more than 20 of Epstein's victims has made the allegation
By Mark Hookham For The…
giuffre-maxwell
gov.uscourts.nysd.447706.1059.0
3 pg
…Doc.892, at 4-10. It found that “the
parties and multiple deponents have reasonably relied on the Protective Order in giving
testimony and producing documents including evidence of assault, medical records, and
emails,” and “[t]hird-party witnesses have…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…in filing a legal document on
their client's behalf which contained those allegations. As a result, the undisputed record
evidence establishes that Dershowitz waged a baseless international media assault on the
honesty, integrity, and professionalism of Edwards and Cassell…
giuffre-maxwell
gov.uscourts.nysd.447706.881.0
8 pg
…A member of the Royal family? A foreigner?
SEXUAL ASSAULT
Has anyone been accused of being involved in sexual assault or sexual abuse of any type
or had a family member involved? (If so, we need to speak to…
giuffre-maxwell
gov.uscourts.nysd.447706.949.0
31 pg
…names and
16 substituting initials and things like that. They don't
17 identify the names of victims of sexual assaults.
18 But the law is such that we have to decide what
19 standard applies. But in any event…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…to, or with whom You
engaged in, any illegal or inappropriate sexual contact, conduct or assault prior to June 1999,
including the names of the individuals involved, the dates of any such illegal or inappropriate
sexual contact, conduct or assault…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…Exhibit. 5, Complaint in Edwards and Cassell
v. Dershowitz. The complaint alleged that Dershowitz had engaged in a “massive public media
assault on the reputation and character” of Cassell and Edwards. Id. at 4. Ms. Giuffre was not a
party…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.49
27 pg
…reasonably
required to respond to the instant motion, and while it surely has the distinct air of “protesting
too much,” I cannot stand mute in the face of this continuing assault on my character. As this
declaration and the accompanying…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…to, or with whom You
engaged in, any illegal or inappropriate sexual contact, conduct or assault prior to June 1999,
including the names of the individuals involved, the dates of any such illegal or inappropriate
sexual contact, conduct or assault…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…the plaintiff in this lawsuit, and
republished all over the world. Professor Dershowitz has done everything in his power to
combat this assault on his reputation, from proclaiming his innocence in public, to marshalling
every bit of information within his…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…the
public interest privilege, and any other applicable privilege. Ms. Giuffre objects to the extent
this seeks information regarding sexual assaults that occurred prior to her involvement with the
Defendant and Jeffrey Epstein. Ms. Giuffre responds as follows: Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1240.0
5 pg
…demonstrated at length at Ms. Maxwell’s recent criminal
trial, this case concerns the widespread abuse, sexual assault and trafficking of minors. It was only
after and because of Intervenors' investigative reporting that Mr. Epstein and Ms. Maxwell were
arrested…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…inter alia, Plaintiff was widely reputed prior to any such
communication to be a liar, a person who falsifies claims of sexual assault, and a sexually
permissive woman, because Plaintiff already had substantial mental and medical conditions that
pre-existed…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.17
13 pg
…motion. Doc.892. Among
other things, the Court found that “the parties and multiple deponents have reasonably relied on
the Protective Order in giving testimony and producing documents including evidence of assault,
medical records, and emails.” Id. at 6. Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.1284.0
17 pg
…is
11 denied. On the consent of the plaintiff and in light of Doe
12 28's status as a victim of sexual assault who continues to
13 experience trauma as a result of these events, Doe 28's name…
giuffre-maxwell
gov.uscourts.nysd.447706.1283.0
17 pg
…is
11 denied. On the consent of the plaintiff and in light of Doe
12 28's status as a victim of sexual assault who continues to
13 experience trauma as a result of these events, Doe 28's name…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.17
25 pg
…the March 21,
2016, meet and confer discussion when Mr. 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)…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.4_1
29 pg
…Cassell alleged that
“[i]mmediately following the filing of what Dershowitz knew to be an entirely proper and well-
founded pleading, Dershowitz initiated a massive public media assault on the reputation and
character of Bradley J. Edwards and Paul G…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…COURT: Yes.
9 MS. McCAWLEY: Sorry. So with respect to the reason
10 why individuals who may have been victims of sexual assault
11 would be confidential, there is case law that we cite in our
12 brief, Doby v…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…the
public interest privilege, and any other applicable privilege. Ms. Giuffre objects to the extent
this seeks information regarding sexual assaults that occurred prior to her involvement with the
Defendant and Jeffrey Epstein. Ms. Giuffre responds as follows: Ms. Giuffre…