…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…
…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…
…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…
…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…
…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.…
…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…
…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)...............................................................................…
…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. …
…that he has never reported to any law enforcement even though he claims that he witnessed potential kidnappings and sexual assaults on children.5 Plaintiff’s claim that Mr. Rizzo is an “example of delay that has harmed [her] ability…
…confidential settlement discussions, terms and documents.” 2016 WL 9782480, at *1. And Litvak was about whether to redact a defendant’s children’s names in connection with exhibits to his sentencing memorandum. 2015 WL 328876, at*1. There, the court…
…females with whom Ms. Maxwell interacted at any of Epstein’s properties knowing that they were under the age of 18 were either members of her own extended family or the minor children of her or Mr. Epstein’s friends…
…that he has never reported to any law enforcement even though he claims that he witnessed potential kidnappings and sexual assaults on children.5 Plaintiff’s claim that Mr. Rizzo is an “example of delay that has harmed [her] ability…
…as a 14 year old, yet announce to the world that she “cried rape,”13 and to humiliate her family (including three minor children) by publicizing she was the victim of domestic abuse in 2015. As the Court saw during…
…privilege did not apply to notes that a woman, Andrea Reynolds, took while watching the cr iminal tria l of Claus von Bu low nor to investigative reports sh e had commissioned about von Bulow's wife's children. Reynolds…
…2010), aff'd, 654 F.3d 748 (7th Cir. 2011) (plaintiffs' discovery regarding financial information from manufacturer and distributor of recalled children's toy was discoverable in a product liability action. Plaintiffs sought punitive damages, and the distributor and manufacturer…
…My client and my reporter write 16 about those things all the time. She writes about children. 17 She writes about public officials whose information needs to be 18 redacted for safety purposes. 19 But the bottom line, your Honor…
…Andrea Reynolds, took while watching the criminal trial of Claus von Bulow nor to investigative reports she had commissioned about von Bulow’s wife’s children. Although Reynolds had been in negotiations at various points to publish articles and was…
…world (if not this Court) his reasons for maintaining his attacks on Ms. Giuffre in the media, in which he has publicly called her a “prostitute” and a “bad mother” to her three minor children. McCawley Dec. at Exhibit 20…
…that he has never reported to any law enforcement even though he claims that he witnessed potential kidnappings and sexual assaults on children.5 Plaintiff’s claim that Mr. Rizzo is an “example of delay that has harmed [her] ability…
…Andrea Reynolds, took while watching the criminal trial of Claus von Bulow nor to investigative reports she had commissioned about von Bulow’s wife’s children. Although Reynolds had been in negotiations at various points to publish articles and was…