giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…Rather, on the way to the detox unit at the hospital, Plaintiff
claimed she had been forcibly sexually assaulted by her friends. Plaintiff’s claim
of forced sexual assault was expressly refuted by the witnesses, who also verified
Plaintiff’s…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…s sex trafficking while attempting to strike down
Ms. Giuffre designations about such things as being sexually assaulted while a child.
Given the extremity of the position she is staking out, it is unsurprising that Defendant’s
entire brief cites…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…confidential).
Part of Defendant’s frantic attempt to discredit Ms. Giuffre is to publicly reveal that she
was sexually assaulted as a 14 year old, yet announce to the world that she “cried rape,”13 and to
humiliate her family…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.6_1
14 pg
…Ex. H (GM00810-00840). Plaintiff alleges she was assaulted by her husband as witnessed
by at least one of their children. Plaintiff’s husband was charged with domestic violence, pled
guilty and was placed on probation.
Designation as Confidential
After…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.1_1
13 pg
…nor disseminate them to third parties. They contain personal, sensitive, and embarrassing
information. Many of them also concern minors and a victim of sexual assault; therefore, they are
protected by various state statutes. Ms. Giuffre requests that this Court maintain…
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.447706.1328.31
13 pg
…RFP No. 1 seeks documents Mr. Pagliuca allegedly ‘reviewed and/or relied upon’ in
allegedly making statements stating that Plaintiff previously made false accusations of sexual
assault.” (Br. at 5). (Emphasis original).
How Defendant purports to distinguish between the actual…
giuffre-maxwell
gov.uscourts.nysd.447706.201.0
5 pg
…of, or witnesses to, sexual abuse and sexual crimes. Indeed, even
when they are plaintiffs, “sexual assault victims are a paradigmatic example of those entitled to a
grant of anonymity.” Doe No. 2 v. Kolko, 242 F.R.D. 193…
giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
…*1 n.1.
Second, the McCord court conceded that safeguarding a sexual assault victim’s identity is
“a compelling reason” not just to redact names, but to “limit the general public’s access to
[complete] documents filed in a case…
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.447706.276.0_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.447706.1248.0
6 pg
…Sept. 4, 2020) (noting that protecting the identity of a sexual assault victim is not “a
basis for withholding the document from the public in its entirety”). In McCord, the Court noted
that courts frequently refer to sexual assault victims…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.8
29 pg
…with Plaintiff’s counsel during which, Plaintiff alleges,
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) that…
giuffre-maxwell
gov.uscourts.nysd.447706.185.8
24 pg
…issue” by making it directly relevant to the case.
Plaintiffs allege that Dershowitz defamed them by “initiat[ing] a massive public media assault on
the reputation and character of [Edwards] and [Cassell] accusing them of intentionally lying in
their filing…
giuffre-maxwell
gov.uscourts.nysd.447706.1118.0
21 pg
…disclosure
that (the intervenor) seeks. Those interests are particularly acute given that
the psychological and emotional wellbeing of survivors of alleged sexual
assaults may be implicated by such a broad disclosure.” Id. at 6.
The Government here seeks all filed…
giuffre-maxwell
gov.uscourts.nysd.447706.1155.0_2
13 pg
…account numbers, and the identities of
underage sexual assault victims.
2
Case 1:15-cv-07433-LAP Document 1155 Filed 11/19/20 Page 4 of 13
that attaches to each of the judicial documents at issue. See Delta…
giuffre-maxwell
gov.uscourts.nysd.447706.892.0
11 pg
…access for criminal investigative purposes civil
deposition transcripts taken under a protective order).
In this case , the parties and multiple deponents have
reasonably relied on the Protective Order in giving testimony
and producing documents including evidence of assault , medical
records …
giuffre-maxwell
gov.uscourts.nysd.447706.354.0
40 pg
…You 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…