gov.uscourts.nysd.447706.671.0.pdf PDF
…OF NEW YORK --------------------------------------------------X .. ............................................. VIRGINIA L. GIUFFRE, Plaintiff, v. …
…OF NEW YORK --------------------------------------------------X .. ............................................. VIRGINIA L. GIUFFRE, Plaintiff, v. …
…Plaintiff, v. 15-cv-07433-RWS ..... GHISLAINE MAXWELL, Defendant. --------------------------------------------------X Declaration of Laura A. Menninger in Supp…
…Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ____________________________/ DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION TO EXCLUDE JEFFREY EPSTEIN PLEA AND NON-PROSEUCTION AGREEMENT AND SEX OFFENDE…
…RWS ..... GHISLAINE MAXWELL, Defendant. --------------------------------------------------X Declaration of Laura A. Menninger in Support of Defendant’s Maxwell’s Reply in Support of Motion in Limine to Exclude Jeffrey Epstein Plea …
…Kellen was specifically identified by the U.S. Attorney’s Office for the Southern District of Florida as a “potential co-conspirator of Epstein” in the non-prosecution agreement it executed with Mr. Epstein as part of his guilty plea…
…either that there is or that there is not a pending criminal investigation of Ms. Maxwell. As for the Non-Prosecution Agreement involving Jeffrey Epstein, my only representation was that the name Ghislaine Maxwell does not appear in that document…
…the Crime Victims Rights Act, 18 U.S.C. § 3771 (“CVRA”), 2 a non-prosecution agreement between Mr. Epstein and the U.S. Attorney’s Office for the Southern District of Florida that is almost nine years old. Through counsel…
… Case 1:15-cv-07433-LAP Document 1199-1 Filed 01/27/21 Page 11 of 13 See GM_00577. Non-prosecution of a rape does not mean the rape didn’t happen, and that in the United States…
…this Court is aware from another pending case, Epstein is a registered sex offender who entered into a non-prosecution agreement (NP A), barring his prosecution for federal crime for his sexual abuse of Ms. Giuffre and multiple other victims…
… Even though the U.S. Attorney’s Office had previously entered into a Non- Prosecution Agreement with Epstein and his potential co-conspirators, the Office would have been entitled to investigate the involvement of any other persons in sex trafficking…
…and non-victim witnesses for the prosecution to testify under pseudonyms “because the disclosure of their identities would necessarily reveal the identities of the alleged victims.” Id. at *1. Accordingly, even bare disclosure of names or information concerning potential non…
…in their pleadings and cannot satisfy it. ARGUMENT I. THE GOVERNMENT CANNOT INTERVENE OR MODIFY THE PROTECTIVE ORDER FOR ACCESS TO NON-JUDICIAL DISCOVERY MATERIALS The Government buries the lead in its Motion. It first seeks four sets of documents…
…121 (2d Cir. 2006). We observe that our holding in Lugosch relies on the general principle that parties may “be assumed to have supported their papers with admissible evidence and non‐ frivolous arguments.” Id. at 122. Insofar as a district…
…both sworn on 30 June 2008. I G leave aside the vital question of the purpose for which the investigations were set up, and summarise the non-contentious evidence in a broadly chronological way. 7. At midday on 12 December…
…Ms. McCawley, on April 11, 2016, filed a pleading in Broward County, Florida court captioned: “Plaintiffs and Non-Party Virginia Giuffre’s Notice Regarding the Parties’ Joint Stipulation of Dismissal.” Menninger Decl. at Ex. B. In that pleading, Messrs. Cassell…
…121 (2d Cir. 2006). We observe that our holding in Lugosch relies on the general principle that parties may “be assumed to have supported their papers with admissible evidence and non‐ frivolous arguments.” Id. at 122. Insofar as a district…
…121 (2d Cir. 2006). We observe that our holding in Lugosch relies on the general principle that parties may “be assumed to have supported their papers with admissible evidence and non‐ frivolous arguments.” Id. at 122. Insofar as a district…
…121 (2d Cir. 2006). We observe that our holding in Lugosch relies on the general principle that parties may “be assumed to have supported their papers with admissible evidence and non‐ frivolous arguments.” Id. at 122. Insofar as a district…
…were a number of cases against Mr. Epstein. There 5 was a series of Jane Doe cases. 6 THE COURT: That arose out of the nonprosecution 7 agreement and all of that. 8 MR. PAGLIUCA: Exactly. 9 So, your Honor…
Case 1:15-cv-07433-LAP Document 1237-1 Filed 01/12/22 Page 1 of 6 Exhibit A Docket Entry Non-Party Plaintiff’s Position Does 122-7 J. Doe 54, J. Doe Unseal and redact only names and…
Comments