giuffre-maxwell
gov.uscourts.nysd.447706.1328.22
22 pg
…lewd and
inventory of law enforcement resources, policies or ascivious offense upon a person less than 16 years old, child abuse,
to mobilization, deployment or tactical operati sexual offense
1'I !rn71 (2)(1) Assets of crime victim …
giuffre-maxwell
gov.uscourts.nysd.447706.1199.4_1
4 pg
…good faith basis for keeping the details of the
rape of a 14 year old girl, and the reactions of Ms. Giuffre' s minor children to domestic violence,
outside of the public realm. See May 18, 2016 letter from J…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.21
19 pg
…policies or ascivious offense upon a person less than 16 years old, child abuse,
to mobilization, deployment or tactical operati s sexual offense
C 119.071 (2)(1) Assets of crime victim C 985.04(1) Juvenile offender records
…
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.447706.881.0
8 pg
…where do you or your spouse work, do you have children (how old),
what are your hobbies, have you ever worked in the legal field.
AGREE TO BE HONEST AND FORTHRIGHT
Does everyone agree that they will tell us…
giuffre-maxwell
gov.uscourts.nysd.447706.363.6
15 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.40.0
8 pg
…is attached in both a redlined version and a clean version (See McCawley Decl. at Exhibit 5),
addresses the following important issues:
Opening Paragraph: Given the fact that this case involves sexual abuse
allegations of a minor child, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.2
56 pg
…19 A. I have a number of friends that
20 have children and friends of mine that have
21 kids and in the invitation of my friends and
22 their kids, I'm sure I may have invited some
23…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…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…
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.447706.1335.5
12 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…highly defamatory allegations that have no basis in fact. Indeed,
his lawsuit was merely a desperate measure by a child abuser to avoid the stigma of the
disclosure of his misconduct. Dershowitz's charges against Edwards and Cassell were and…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.23
9 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.89.0
10 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.35
10 pg
…A. Same age as me.
(Tr. at 62:10-14).
It is an outright misrepresentation to this Court that Ms. Maxwell admitted to any sexual
contact with a “multiple different girls.” A “girl” is a female child. See, e.g.…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.5
56 pg
…19 A. I have a number of friends that
20 have children and friends of mine that have
21 kids and in the invitation of my friends and
22 their kids, I'm sure I may have invited some
23…
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.447706.1257.23
10 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.15
43 pg
…Southern District of New York
(the "New York case"). The case concerns a defamation action brought by a child victim of
convicted pedophile Jeffrey Epstein against his live-in girlfriend who assisted him in procuring
underage girls, including the plaintiff…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.9_7
56 pg
…19 A. I have a number of friends that
20 have children and friends of mine that have
21 kids and in the invitation of my friends and
22 their kids, I'm sure I may have invited some
23…
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