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.447706.1340.0
1 pg
…PRESKA, Senior United States District Judge:
It has come to the Court’s attention that several articles
have been published in the domestic and international press
asserting that a woman identified as “Banu Kucukkoylu” is “Doe 102”
in this case…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.1_1
13 pg
…Giuffre as a
fourteen-year-old victim of rape. Other police reports show her to be the victim of other crimes,
including domestic violence. Defendant should not be allowed to make these police reports public,
nor disseminate them to third…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…reports describing Ms. Giuffre as a
fourteen-year-old victim of rape. Other police reports show her to be the victim of other crimes,
including domestic violence. Defendant should not be allowed to make these police reports
public, nor disseminate…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…reports describing Ms. Giuffre as a
fourteen-year-old victim of rape. Other police reports show her to be the victim of other crimes,
including domestic violence. Defendant should not be allowed to make these police reports
public, nor disseminate…
giuffre-maxwell
gov.uscourts.nysd.447706.749.0
9 pg
…22
14. Plaintiff’s husband’s domestic violence against her in March 2015 is probative of other
intervening causes of emotional distress and related damages (Motion in Limine 14) 23
15. Plaintiff’s lies about her age and the year…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…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 receiving Defendant’s production…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.17
25 pg
…without further conferral.
DOCUMENT REQUEST NO. 24
Produce all tax returns filed with any taxing entity (either foreign or domestic) from
January 2015 to the present by You or on Your behalf, or on behalf of any entity in which…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.35
10 pg
…the Court -- whether Plaintiff’s
publicly available criminal files should be deemed “confidential” under the Protective Order.
None of the witnesses has anything to do with Plaintiff’s false claims of sexual assault as a child,
nor her domestic violence…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.33
24 pg
…Instead, she was treated at a hospital for a
domestic violence incident in which her husband strangled and punched her. This highly
15
Case 1:15-cv-07433-LAP Document 1320-33 Filed 01/03/24 Page 19 of…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.4
35 pg
…Our ultimate goal is a home for
domestic minor sex trafficking survivors.
Our contact information is:
doorstofreedom.com
[email protected]
843-817-0740
I am going to forward your information to our Attorney Generals office as
Marie Sazehn has…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.36_1
35 pg
…Our ultimate goal is a home for
domestic minor sex trafficking survivors.
Our contact information is:
doorstofreedom.com
[email protected]
843-817-0740
I am going to forward your information to our Attorney Generals office as
Marie Sazehn has…
giuffre-maxwell
gov.uscourts.nysd.447706.179.0
22 pg
…presumption that the lawyer is hired ‘as such’ to give ‘legal advice,’ whether the subject of the
advice is criminal or civil, business, tort, domestic relations, or anything else.” United States v.
Chen, 99 F.3d 1495, 1501 (9th Cir…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.23
10 pg
…the Court -- whether Plaintiff’s
publicly available criminal files should be deemed “confidential” under the Protective Order.
None of the witnesses has anything to do with Plaintiff’s false claims of sexual assault as a child,
nor her domestic violence…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.39
35 pg
…Our ultimate goal is a home for
domestic minor sex trafficking survivors.
Our contact information is:
doorstofreedom.com
[email protected]
843-817-0740
I am going to forward your information to our Attorney Generals office as
Marie Sazehn has…
giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
…to the present.
DOCUMENT REQUEST NO. 24
Produce all tax returns filed with any taxing entity (either foreign or domestic) from
January 2015 to the present by You or on Your behalf, or on behalf of any entity in which…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.7
30 pg
…WITHHELD,” AND THEREFORE, NO
PREJUDICE
Defendant cannot be taken seriously when she claims that “Plaintiff is obviously trying to
hide” her treatment related to domestic violence,
Given that fact,
Defendant’s incendiary claim defies logic. Al…
giuffre-maxwell
1320-39
35 pg
…Our ultimate goal is a home for
domestic minor sex trafficking survivors.
Our contact information is:
doorstofreedom.com
[email protected]
843-817-0740
I am going to forward your information to our Attorney Generals office as
Marie Sazehn has…
giuffre-maxwell
1320-17
25 pg
…without further conferral.
DOCUMENT REQUEST NO. 24
Produce all tax returns filed with any taxing entity (either foreign or domestic) from
January 2015 to the present by You or on Your behalf, or on behalf of any entity in which…
giuffre-maxwell
1320-33
24 pg
…Instead, she was treated at a hospital for a
domestic violence incident in which her husband strangled and punched her. This highly
15
Case 1:15-cv-07433-LAP Document 1320-33 Filed 01/03/24 Page 19 of…
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