giuffre-maxwell
gov.uscourts.nysd.447706.1.0
12 pg
…arises out of Defendant Maxwell’s defamatory statements against
Plaintiff Giuffre. As described below, Giuffre was a victim of sexual trafficking and abuse while
she was a minor child. Defendant Maxwell not only facilitated that sexual abuse but, most
recently…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…the Court should grant the
motion. 1
1
As minor victims of sexual offenses, Jane Doe #3 and Jane Doe #4 desire to proceed by
way of pseudonym for the same reasons that Jane Doe #1 and Jane Doe #2…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.6
10 pg
…against the United States, that is, to use a facility or means
of interstate or foreign commerce to knowingly persuade, induce, or onticc .
minor femalea to engage in proatitution, in violation ofTitle 18, United States
Code, Section 2422(b); ,u…
giuffre-maxwell
gov.uscourts.nysd.447706.562.1
13 pg
…arises out of Defendant Maxwell’s defamatory statements against
Plaintiff Giuffre. As described below, Giuffre was a victim of sexual trafficking and abuse while
she was a minor child. Defendant Maxwell not only facilitated that sexual abuse but, most
recently…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…the Court should grant the
motion. 1
1
As minor victims of sexual offenses, Jane Doe #3 and Jane Doe #4 desire to proceed by
way of pseudonym for the same reasons that Jane Doe #1 and Jane Doe #2…
giuffre-maxwell
1320-9
10 pg
…the Court should grant the
motion. 1
1
As minor victims of sexual offenses, Jane Doe #3 and Jane Doe #4 desire to proceed by
way of pseudonym for the same reasons that Jane Doe #1 and Jane Doe #2…
giuffre-maxwell
gov.uscourts.nysd.447706.24.1
13 pg
…arises out of Defendant Maxwell’s defamatory statements against
Plaintiff Giuffre. As described below, Giuffre was a victim of sexual trafficking and abuse while
she was a minor child. Defendant Maxwell not only facilitated that sexual abuse but, most
recently…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.3
10 pg
…the Court should grant the
motion. 1
1
As minor victims of sexual offenses, Jane Doe #3 and Jane Doe #4 desire to proceed by
way of pseudonym for the same reasons that Jane Doe #1 and Jane Doe #2…
giuffre-maxwell
gov.uscourts.nysd.447706.185.4
10 pg
…1).
Generally, they allege that the respondent Government violated their rights under the CVRA by
failing to consult with them before negotiating a non-prosecution agreement with Jeffrey Epstein,
who subjected them to various sexual crimes while they were minors. …
giuffre-maxwell
gov.uscourts.nysd.447706.363.4
11 pg
…1).
Generally, they allege that the respondent Government violated their rights under the CVRA by
failing to consult with them before negotiating a non-prosecution agreement with Jeffrey Epstein,
who subjected them to various sexual crimes while they were minors. …
giuffre-maxwell
gov.uscourts.nysd.447706.1074.5
11 pg
…1).
Generally, they allege that the respondent Government violated their rights under the CVRA by
failing to consult with them before negotiating a non-prosecution agreement with Jeffrey Epstein,
who subjected them to various sexual crimes while they were minors. …
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…exercising its inherent “supervisory powers.”26 A
security numbers. We have also redacted the names of alleged minor victims of
sexual abuse from deposition testimony and police reports, as well as deposition
responses concerning intimate matters where the questions were…
giuffre-maxwell
gov.uscourts.nysd.447706.1028.0
5 pg
…he might
consider benign and insignificant. However, Doe #100 likely has significant privacy
and other interests in the unsealing of materials in which a person alleges he sexually
abused a minor. In the second disclosure, he has a weighty “countervailing…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…exercising its inherent “supervisory powers.”26 A
security numbers. We have also redacted the names of alleged minor victims of
sexual abuse from deposition testimony and police reports, as well as deposition
responses concerning intimate matters where the questions were…
giuffre-maxwell
gov.uscourts.nysd.447706.978.0
27 pg
…exercising its inherent “supervisory powers.”26 A
security numbers. We have also redacted the names of alleged minor victims of
sexual abuse from deposition testimony and police reports, as well as deposition
responses concerning intimate matters where the questions were…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.1
13 pg
…With regard to Ms. Giuffre, the motion indicated that when she was a minor, Jeffrey
Epstein had trafficked her to Dershowitz and Prince Andrew (among others) for sexual purposes.
Jane Doe No. 3 stated that she was prepared to prove…
giuffre-maxwell
gov.uscourts.nysd.447706.941.0
6 pg
…19, 2018).
-2-
Case 1:15-cv-07433-RWS Document 941 Filed 04/20/18 Page 3 of 6
Because of the sensitive nature of the materials designated as confidential,
involving allegations of sexual abuse and trafficking of minors…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.45
13 pg
…With regard to Ms. Giuffre, the motion indicated that when she was a minor, Jeffrey
Epstein had trafficked her to Dershowitz and (among others) for sexual purposes.
Jane Doe No. 3 stated that she was prepared to prove her proffer…
giuffre-maxwell
gov.uscourts.nysd.447706.977.0
27 pg
…exercising its inherent “supervisory powers.”26 A
security numbers. We have also redacted the names of alleged minor victims of
sexual abuse from deposition testimony and police reports, as well as deposition
responses concerning intimate matters where the questions were…
giuffre-maxwell
gov.uscourts.nysd.447706.1045.0
2 pg
…a joint proposed redacted Decided Motions List to be filed on the
public docket. Because the parties identified two minor numbering changes (with respect to
DEs 272 and 423), we also hereby provide (under seal) an updated unredacted Decided
Motions…
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