….............. 60 5. The January 2015 statement accurately denied that Ms. Maxwell created and distributed child pornography and that the Government knows of and possesses such child pornography. .................................…
…Daily News, April 7, 2015. Defendant has subjected Jane Doe No. 3 to horrific public attacks including publicly calling her a “prostitute” and a “bad mother” to her three minor children. See Exhibit 2, Local 10 News, January 22, 2015…
…warranting a broad protective order, Defendant now wants to publicize police reports concerning Ms. Giuffre - most of them from when she was a child, some of them concerning her being raped when only 14 years. Defendant’s challenge to Ms…
…United States, 134 S. Ct. 1710 (2014) (arguing before the Supreme Court on behalf of “Amy,” a child pornography victim seeking restitution); In re Antrobus, 519 F.3d 1123 (10th Cir. 2008) (arguing for opportunity for victim to deliver a…
…fact. PLAINTIFF’S MISSTATEMENTS OF FACT 1. 1 2. “Ms. Giuffre was the child victim of sexual abuse, which is undisputed.” (Reply at 9) If there is one thing this litigation makes clear, it is heavily disputed that Ms…
…to have sex with and her knowledge of Mr. Epstein’s sex with a number of people. She was asked questions about “sex toys”, pornographic images, child pornography, and nudity at Mr. Epstein’s house. Ms. Maxwell answered these questions…
…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…
…Bank AG, 582 F. Supp. 2d 528 (S.D.N.Y. 2008)....................................................................................... 17 E.E.O.C. v. Nat’l Children’s Ctr., Inc., 146 F.3d 1042 (D.C. Cir. 1998) ................................................................................................ 15 Globe Newspaper Co. v. …
…Giuffre has been involved, either as a witness or a party, in three other civil cases relating to the sexual abuse she suffered as a child. Therefore, Defendant’s Requests for Production intentionally target a high volume of privileged documents…
…royal stepped down from his role as a U.K. trade ambassador after he was photographed with Epstein in New York. Prince Andrew is the second son and third child of Queen Elizabeth II and Prince Philip, Duke of Edinburgh…
…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…
…for it — leaves out the fact that this is why we have laws in the United States to protect minor children who are groomed and sexually trafficked by adults.' Epstein served 13 months in a Florida prison after pleading guilty…
…2019) ...................................................................................................... 4, 6 Craig v. Harney, 331 U.S. 367 (1947) .................................................................................................................... 6 E.E.O.C. v. Nat’l Children's Ctr., Inc., 146 F.3d 1042 (D.C. C…
…valid and necessary interrogatory questions. The objections Plaintiff persists in asserting are improper, and all but one category of documents (pictures of her children) must be produced. Response to the Interrogatories is necessary prior to Ms. Maxwell’s deposition to…
…2d Cir. 2016)............................................................................................... passim Craig v. Harney, 331 U.S. 367 (1947) .................................................................................................................... 1 E.E.O.C. v. Nat’l Children's Ctr., Inc., 146 F.3d 1042 (D.…
…Deutsche Bank AG, 582 F. Supp. 2d 528 (S.D.N.Y. 2008) .................................................................................................... 9 Equal Emp't Opportunity Comm'n v. Nat'l Children's Ctr., Inc., 146 F.3d 1042 (D.C. Cir. 1998)...............................................................................…
…10) ................................................. 19 11. Plaintiff put her full childhood history and character at issue (Motion in Limine 11) .. 20 12. Victims Refuse Silence is a sham not-for-profit established to create a claim for defamation per se (Motion in Limine…
…contact with Epstein, Dershowitz, and others; (2) A Statement of Undisputed Facts containing 120 paragraphs of supported factual material detailing Epstein's sexual abuse of children; (3) Deposition excerpts identifying Dershowitz as one of Epstein's associates; (4) Deposition excerpts…
…In addition, Maxwell flew with plaintiff when she was a minor child in 2000 on Jeffrey Epstein’s planes. The flight logs reveal that Maxwell continued to actively travel with Jeffrey Epstein and other unidentified “female” passengers through at least…
… Due to safety concerns with respect to Ms. Giuffre and her minor children, she is not at liberty to reveal her present residential location. To ensure that Defendant is not prejudiced by the failure to provide information about Ms. Giuffre…
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