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.447706.1259.0
17 pg
…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…
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.447706.936.0
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.447706.185.7
26 pg
…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…
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.447706.1201.26
28 pg
…the
Afflecks! Jennifer
Garner 'will join ex Ben
…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.8
9 pg
…Conn. 2014)
(protective order granted with respect to personal information of nonparties, including home
addresses, email addresses, phone numbers, dates of birth, children’s names, financial account
numbers, and social security numbers); see also Liz Claiborne, Inc., v. Mademoiselle Knitwear…
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.447706.1328.44
14 pg
…Did you know that Jeffrey Epstein received 13 MR. RHEINHART: That question was asked
14 sexual gratification from directing other…
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.447706.1199.1_1
13 pg
…particularly as they include reports depicting her as
the victim of domestic violence. In fact, the domestic violence report also identifies and describes
her minor children.
Accordingly, Ms. Giuffre requests that this Court grant her motion for a Protective Order
…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 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.
5…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…phone numbers, dates of birth, children’s names, financial account
numbers, and social security numbers).
Request 22 (All Modeling Contracts Signed or Entered into By You):
Non-party Ransome provided testimony that she did very little modeling while in New…