…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 …
…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…
…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…
…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…
…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…
…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…
…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…
…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…
…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.…
…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…
…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…
…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…
…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…
…N.Y. Jan. 26, 2017) (complaint). Maxwell has now been accused of running or being involved in a child sex trafficking ring in multiple lawsuits. Maxwell’s involvement in sex trafficking is newsworthy on its face. Indeed, the Daily Mail…
…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…
…of . 12. Attached hereto as Sealed Composite Exhibit 10 is a true and correct copy of Deposition Excerpts from Detective Joseph Recarey and the Article “How Alan Dershowitz Bullied Rape Victims to Protect a Serial Child Molester.” 13. Attached hereto…
…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…
…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…
…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…
…disregard of the Court’s compelling reasons for permitting the parties to seal materials. This case involved plaintiff’s claim she had been “forced” to be a “child” “sex slave” for a long list of prominent men. She accused Ms…
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