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.447706.751.12
3 pg
…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…
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.447706.99.0
22 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.551.0
17 pg
…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.…
giuffre-maxwell
gov.uscourts.nysd.447706.957.0
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.447706.936.0
21 pg
…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)...............................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.589.0
24 pg
…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-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…documents responsive to this Request, including things like mainstream newspapers,
magazines, videos, DVDs or other media or family photographs which contain depictions of
female children, including Maxwell herself as a child.
b. Maxwell’s Objections Fail, as the Request Seeks…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
… 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…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
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.447706.1328.41
31 pg
…a close friend, flew on Jeffrey Epstein’s private jet 15 times
from 1996 through 2006, which was during the time period that Jeffrey was actively assaulting a number of minor
children. Twice Dershowitz flew with Sarah Kellen, who was…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…in the assessment of a juvenile is confidential. Finally, certain of
the police reports implicate Ms. Giuffre’s involvement with the Florida Department of Children
and Families, see e.g., GM_00750, and if such reports are part of the…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…was then fifteen years old) to come to Epstein’s
mansion in a fashion very similar to the manner in which Epstein and his other co-conspirators
coerced dozens of other children (including Jane Doe #1 and Jane Doe #2)…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.42
9 pg
… I mean he said, for example, he's
only been at Jeffrey Epstein's house once and it was with his wife and children. What
if it comes out that he was actually there, and there are photographs of him…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
… 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…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.50
15 pg
…Inc., 435 U.S. 589, 609 (1978).
In their tortured efforts to assert that it was proper to publicly accuse Professor
Dershowitz of raping children, Ms. Giuffre’s lawyers unwittingly reveal just how baseless these
accusations really are. The Reply…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.31
10 pg
…to protect a serial
child molester
Rania Khalek Clpeople / rania-khalekl Power Suits Clblog/ power-s uitsl 10 January 2015
Hatvard law professor Alan Qershowjtz