giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…any identifying information, for example, their Social Security
21 number or an address be able to be protected for those that are
22 coming to testify. I know that makes it a little bit more
23 difficult, but if we…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…those events is protected from disclosure by law. Florida
statutes protect “[a]ny information in a videotaped statement of a minor who is alleged to be or
who is a victim of sexual battery . . . which reveals that minor’s identity.”…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.1_1
13 pg
…Many of them also concern minors and a victim of sexual assault; therefore, they are
protected by various state statutes. Ms. Giuffre requests that this Court maintain the confidentiality
designations over these police reports and direct the Defendant to disclose…
giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
… Intervenors’ First Proposition of Law: For minor victims of sexual abuse, “redactions
should be applied sparingly to shield only information that would identify those who
have not already been publicly identified.” DE 1248, at 2.
The Reality: Courts routinely seal…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.17
25 pg
…Court or any Orders of the Court.
3. Ms. Maxwell objects to the Requests to the extent they seek documents or
information protected by the attorney/client privilege, the work-product doctrine, Rule 408 of the
Federal Rules of Evidence…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.4_1
4 pg
…I have several.
First, Florida statutes protect "[a]ny information in a videotaped statement of a minor
who is alleged to be or who is a victim of sexual battery ... which reveals that minor' s identity."
Fla. Stat.§ 119.071…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.18
50 pg
…This
Court’s Order ............................................................................................23
5. Information About Ms. Giuffre’s Sexual Abuse is Protected by
Florida Statutes ..................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1122.0_2
13 pg
…on the subject matter in question.
The second circumstance establishing a compelling need for the USVI to gain access
through modification of the Protective Order is that even the identity of the deponent witnesses is
not known or otherwise knowable…
giuffre-maxwell
1320-17
25 pg
…Court or any Orders of the Court.
3. Ms. Maxwell objects to the Requests to the extent they seek documents or
information protected by the attorney/client privilege, the work-product doctrine, Rule 408 of the
Federal Rules of Evidence…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…that it seeks information protected by the attorney client and work product
privileges. Ms. Giuffre objects to this interrogatory in that it is not limited in time or to the
subject nature of this litigation.
8. Identify the individuals referenced…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…due to holding both
French and British passports, she has the ability to 'live beyond the reach of extradition
indefinitely'.
Prosecutor Moe argued: 'She is good at living under an assumed identity. There really
can be no question that she…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…federal court proceedings. As
a result, that filing is indisputably protected by Florida's broad and absolute litigation privilege.
Consequently, plaintiffs' motion for summary judgment as it relates to the pending counterclaim
against them should also be granted.
ARGUMENT
II. …
giuffre-maxwell
gov.uscourts.nysd.447706.1328.4
40 pg
…4 Filed 01/05/24 Page 5 of 40
that Ms. Maxwell has published “numerous” false statements, yet Plaintiff stubbornly refuses to
identify each of these allegedly false statements. Interrogatory No. 6 asked simply that for each
allegedly false statement…
giuffre-maxwell
gov.uscourts.nysd.447706.99.0
22 pg
…demonstrates exactly why the Motion was necessary. Not until the
Motion was filed did Plaintiff “supplement” her privilege log, specifically identify some of the
documents she is withholding, produce relevant documents clearly in her possession, concede to
providing information previously…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.8
29 pg
…Florida’s open-records laws. Subsection (2)(h)1.b. provides that “the
identity of a person who is a victim of any sexual offense” (emphasis supplied) is exempt from
the open-records laws. Here, the defense obtained identity-redacted…
giuffre-maxwell
gov.uscourts.nysd.447706.71.3
40 pg
…that it seeks information protected by the attorney client and work product
privileges. Ms. Giuffre objects to this interrogatory in that it is not limited in time or to the
subject nature of this litigation.
8. Identify the individuals referenced…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.1
18 pg
…protected from public dissemination by Florida law.
Specifically, Florida statutes protect “[a]ny information in a videotaped statement of a
minor who is alleged to be or who is a victim of sexual battery . . . which reveals that minor’s
identity…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.1
13 pg
…the motion briefly
proffered the circumstances that would qualify the two women as “victims” eligible to assert
rights under the CVRA. See 18 U.S.C. 3771(e) (defining “crime victim” protected under the
Act). With regard to Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.45
13 pg
…the motion briefly
proffered the circumstances that would qualify the two women as “victims” eligible to assert
rights under the CVRA. See 18 U.S.C. 3771(e) (defining “crime victim” protected under the
Act). With regard to Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.6_1
14 pg
…Statutes
Plaintiff also cites Colorado statutes which, she claims, support the proposition that her
identity as the victim of domestic violence is protected by Colorado law. It is not. Section 13-
90-107(k),3 is a testimonial privilege statute…