giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
…The Intervenors’ requests to unseal should be denied.
A. 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…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.31
13 pg
…This Court should Order Production of Documents Responsive to Requests
Nos. 1-3
Defendant characterizes the police reports (and information therein) concerning Ms.
Giuffre as a minor as both “highly relevant” (Br. at 4) and “irrelevant” to this action (Br…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.16
8 pg
…164
Case 1:15-cv-07433-LAP Document 1328-16 Filed 01/05/24 Page 3 of 8
26 28
l to his house to sexunlly molest; is thnt right? l minor females?
2 MR. VAREM/\ : Object to the form …
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.447706.1219.11
13 pg
…This Court should Order Production of Documents Responsive to Requests
Nos. 1-3
Defendant characterizes the police reports (and information therein) concerning Ms.
Giuffre as a minor as both “highly relevant” (Br. at 4) and “irrelevant” to this action (Br…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.3
19 pg
…- Sl 20 Cr. 330 (AJN)
GHISLAINE MAXWELL,
Defendant.
X
COUNT ONE
(Conspiracy to Entice Minors to Travel to Engage in
Illegal Sex Acts)
The Grand Jury charges:
…
giuffre-maxwell
gov.uscourts.nysd.447706.968.1
1 pg
…The task of identifying
and making specific redactions in such a substantial volume is perilous; the
consequences of even a seemingly minor error may be grave and are irrevocable.
Moreover, although I share the majority’s concern about avoiding delay…
giuffre-maxwell
gov.uscourts.nysd.447706.1070.0
1 pg
…without redaction after ninety (90) calendar days.
This process may only be used to redact the following personal data identifiers: Social Security
numbers; dates of birth; minors’ names; and financial account numbers. See Federal Rule of Civil Procedure
5.2…
giuffre-maxwell
gov.uscourts.nysd.447706.1197.0_1
1 pg
…without redaction after ninety (90) calendar days.
This process may only be used to redact the following personal data identifiers: Social Security
numbers; dates of birth; minors’ names; and financial account numbers. See Federal Rule of Civil Procedure
5.2…
giuffre-maxwell
gov.uscourts.nysd.447706.1022.0
1 pg
…without redaction after ninety (90) calendar days.
This process may only be used to redact the following personal data identifiers: Social Security
numbers; dates of birth; minors’ names; and financial account numbers. See Federal Rule of Civil Procedure
5.2…
giuffre-maxwell
gov.uscourts.nysd.447706.32.0
1 pg
…without redaction after
ninety (90) calendar days.
This process may only be used to redact the following personal data identifiers: Social-
Security numbers; dates of birth; minors’ names; and financial account numbers. See Federal
Rule of Civil Procedure 5.2…
giuffre-maxwell
gov.uscourts.nysd.447706.382.0
2 pg
…pending motion to intervene and to unseal documents.
2. In my previous declaration, I characterized the offenses to which Jeffrey Epstein
pleaded guilty as “involving sex with minors” (¶ 7) and “related to sex with minors” (¶ 10).
These statements were imprecise…
giuffre-maxwell
gov.uscourts.nysd.447706.69.2
21 pg
…Fairway Lakes Drive, Boynton Beach, FL 33472
Telephone number unknown at this time
May have information about Ghislaine Maxwell and Jeffrey Epstein’s sexual
trafficking conduct and interaction with underage minors.
4. Maria Alessi
6791 Fairway Lakes Drive, Boynton Beach…
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.447706.40.0
8 pg
…is attached in both a redlined version and a clean version (See McCawley Decl. at Exhibit 5),
addresses the following important issues:
Opening Paragraph: Given the fact that this case involves sexual abuse
allegations of a minor child, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.18
5 pg
…age*
344) minor*
345) daily* w/10 mail*
346) daily* w/10 news*
347) lie*
348) obvious* w/10 lie*
349) sex w/3 toy*
350) nipple*
351) schoolgirl
352) school w/3 girl
353) us w/3 att*
354…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.2
12 pg
…sentences and
common words, also causing the same question to be posed to her multiple times. For example,
defendant pretended not to understand the question, “Do you believe that Epstein abused
minors?,” causing it to be repeated multiple times.
Q. . …
giuffre-maxwell
gov.uscourts.nysd.447706.1328.44
14 pg
…Fifth . 7 would rly from place to 11lacc for the purpose of
8 Q Isn't take true you have IJeen on Jeffrey 8 engaging i11 sexual activity with minors at his
9 Epstein's airplane with Dong Band, nm…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.1_1
13 pg
…nor disseminate them to third parties. They contain personal, sensitive, and embarrassing
information. 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…
giuffre-maxwell
gov.uscourts.nysd.447706.1312.0
9 pg
…and much of the information that
non-parties seek to keep sealed, have already been presented to a jury at a public criminal trial
where only minor victims were permitted to testify under a pseudonym. See United States v.
Maxwell…
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