giuffre-maxwell
gov.uscourts.nysd.447706.724.0
7 pg
…many if not all of the Complaints against Epstein pursuant to his plea agreement
to fund such lawsuits against him were styled as “Jane Doe” to protect the privacy of his
underage victims.
1
Case 1:15-cv-07433-LAP…
giuffre-maxwell
gov.uscourts.nysd.447706.849.0
94 pg
…21 the 302 motion; and there are three that seem to me to go
22 together -- the references to the Florida action, the CVRA
23 action; the Epstein plea agreement and nonprosecution, and
24 registration; and the victim notification letter. …
giuffre-maxwell
gov.uscourts.nysd.447706.847.0
94 pg
…21 the 302 motion; and there are three that seem to me to go
22 together -- the references to the Florida action, the CVRA
23 action; the Epstein plea agreement and nonprosecution, and
24 registration; and the victim notification letter. …
giuffre-maxwell
gov.uscourts.nysd.447706.1330.6
10 pg
…but not limited to Sarah Kellen.
against any potential co-conspirators of Epstein
Adriana Ross, Lesley Oro~ or Nadia MarcinkoviL Further,
upon execution of this
federal Gr…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.18
23 pg
…two other women, not plaintiff, litigated for I think
14 seven years now whether or not they should have been informed
15 earlier about whatever plea agreement was going to go on with
16 Mr. Epstein.
17 Well, December 30…
giuffre-maxwell
gov.uscourts.nysd.447706.23.0
32 pg
…Court found that joinder of another victim was
unnecessary because the two named plaintiffs were sufficient to represent the group of victims in their claim that the
government failed to properly notify them of the plea agreement with Jeffrey Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.4
21 pg
…namely, whether the
United States District Attorney for the Southern District of Florida failed to discharge its
statutorily-mandated duty to Epstein’s victims upon entering into a plea agreement with Epstein.
Ms. Giuffre’s supposed 2013 contemplation of the…
giuffre-maxwell
gov.uscourts.nysd.447706.672.0
3 pg
…Plaintiff,
v. 15-cv-07433-RWS
.....
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X
Declaration of Laura A. Menninger in Supp…
giuffre-maxwell
gov.uscourts.nysd.447706.741.0
3 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.789.0
3 pg
…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
giuffre-maxwell
gov.uscourts.nysd.447706.308.0
7 pg
…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. She has relevant information…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…241
(adding 18 U.S.C. § 3771(a)(9) to give crime victims “[t]he right to be informed in a timely
manner of any plea bargain or deferred prosecution agreement).
1
See generally Paul G. Cassell, Nathanael J…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…all other matters would have
2 to be -- obviously it's a public trial and so we would not be
3 able to protect the other specifics.
4 THE COURT: Have you all reached an agreement to that
5 effect…
giuffre-maxwell
gov.uscourts.nysd.447706.562.1
13 pg
…her.
11. In September 2007, Epstein entered into a Non-Prosecution Agreement (“NPA”)
that barred his prosecution for numerous federal sex crimes in the Southern District of Florida.
12. In the NPA, the United States additionally agreed that it would…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.14_2
40 pg
…240, 241
(adding 18 U.S.C. § 3771(a)(9) to give crime victims “[t]he right to be informed in a timely
manner of any plea bargain or deferred prosecution agreement).
1
See generally Paul G. Cassell, Nathanael J…
giuffre-maxwell
1320-18
40 pg
…241
(adding 18 U.S.C. § 3771(a)(9) to give crime victims “[t]he right to be informed in a timely
manner of any plea bargain or deferred prosecution agreement).
1
See generally Paul G. Cassell, Nathanael J…
giuffre-maxwell
gov.uscourts.nysd.447706.160.0
12 pg
…specifically identified both Kellen and Marcinkova as among four named “potential co-
conspirators of Epstein” in the non-prosecution agreement it executed with Epstein as part of his
guilty plea to Florida state sex offense charges. See Non-Prosecution Agreement…
giuffre-maxwell
gov.uscourts.nysd.447706.1.0
12 pg
…her.
11. In September 2007, Epstein entered into a Non-Prosecution Agreement (“NPA”)
that barred his prosecution for numerous federal sex crimes in the Southern District of Florida.
12. In the NPA, the United States additionally agreed that it would…
giuffre-maxwell
gov.uscourts.nysd.447706.24.1
13 pg
…her.
11. In September 2007, Epstein entered into a Non-Prosecution Agreement (“NPA”)
that barred his prosecution for numerous federal sex crimes in the Southern District of Florida.
12. In the NPA, the United States additionally agreed that it would…
giuffre-maxwell
gov.uscourts.nysd.447706.961.0
9 pg
…not take Ms. Giuffre’s silence on factual
assertions irrelevant to the pending dispute as agreement on their veracity.
1
Case 1:15-cv-07433-LAP Document 961 Filed 12/12/18 Page 2 of 9
Indeed, it appears…
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