giuffre-maxwell
gov.uscourts.nysd.447706.727.0
3 pg
…Giuffre,
Plaintiff, 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 IN LIMINE
TO EXCLUDE SUPPLEMENTAL REPORT OF DR. JAMES J…
giuffre-maxwell
gov.uscourts.nysd.447706.1050.0
12 pg
…LEWIN
PAUL M. KRIEGER
24
25
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 1050 Filed 04/15/20 Page 2 of 12 2
K3VQgiuC
1 (The Court and all parties appearing…
giuffre-maxwell
gov.uscourts.nysd.447706.1339.0
3 pg
…and, since that time, the
Court has received reports that information that was subject to
continued sealing was inadvertently disclosed. The Court writes
now to clarify the unsealing process intended by its December 18
Order.
First, the Court reiterates its…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.5
3 pg
…Deposition of Louella Rabuyo.
8. Attached hereto as Sealed Composite Exhibit 6 are true and correct copies of
Palm Beach Police Report (GIUFFRE000064) and Excerpts from June 21, 2016 Deposition of
Detective Joseph Recarey.
I declare under penalty of perjury…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…and DRONEY, Circuit Judges.
Intervenors‐Appellants Alan Dershowitz, Michael Cernovich,
and the Miami Herald Company (with reporter Julie Brown) appeal
from certain orders of the United States District Court for the Southern
District of New York (Robert W. Sweet, Judge…
giuffre-maxwell
gov.uscourts.nysd.447706.1010.0
3 pg
…2019
Page 2
Even with that assumption, however, we report on behalf of defendant Ghislaine
Maxwell that we have engaged in a good faith evaluation of the work that must be done
to comply with Paragraphs 2, 3, and 5…
giuffre-maxwell
gov.uscourts.nysd.447706.1226.0
4 pg
…not been seamless, of course. Two examples stand out.
First, the parties report they have failed to effectuate service on many of the non-parties.
Although disappointing, we acknowledge this failing is mitigated, at least in part, by the Court…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…and DRONEY, Circuit Judges.
Intervenors‐Appellants Alan Dershowitz, Michael Cernovich,
and the Miami Herald Company (with reporter Julie Brown) appeal
from certain orders of the United States District Court for the Southern
District of New York (Robert W. Sweet, Judge…
giuffre-maxwell
gov.uscourts.nysd.447706.978.0
27 pg
…and DRONEY, Circuit Judges.
Intervenors‐Appellants Alan Dershowitz, Michael Cernovich,
and the Miami Herald Company (with reporter Julie Brown) appeal
from certain orders of the United States District Court for the Southern
District of New York (Robert W. Sweet, Judge…
giuffre-maxwell
gov.uscourts.nysd.447706.977.0
27 pg
…and DRONEY, Circuit Judges.
Intervenors‐Appellants Alan Dershowitz, Michael Cernovich,
and the Miami Herald Company (with reporter Julie Brown) appeal
from certain orders of the United States District Court for the Southern
District of New York (Robert W. Sweet, Judge…
giuffre-maxwell
gov.uscourts.nysd.447706.1254.0
18 pg
…Doe 73
BY: DENIS P. KELLEHER, JR.
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 1254 Filed 04/26/22 Page 2 of 18 2
M4j2GiuC
1 THE COURT: Good morning, counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.1034.0
16 pg
…fulsome list
provided by Defendants, which strikes the names of reporters,
1
Case 1:15-cv-07433-LAP Document 1034 Filed 03/19/20 Page 2 of 16
Plaintiff’s medical providers, and law enforcement personnel
but retains all…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…other under-aged
girls). Epstein instructed Jane Doe #3 that she was to give the Prince whatever he demanded and
required Jane Doe #3 to report back to him on the details of the sexual abuse. Maxwell
facilitated Prince Andrew…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…an orgy with numerous other under-aged
girls). Epstein instructed Jane Doe #3 that she was to give whatever he demanded and
required Jane Doe #3 to report back to him on the details of the sexual abuse. Maxwell
facilitated …
giuffre-maxwell
gov.uscourts.nysd.447706.139.0
7 pg
…607 F3d 923, 947 (2d Cir
2010) (granting mandamus relief with regard to District Court’s order granting motion to compel
police reports, and holding that though the District Court correctly determined that the law
enforcement privilege applied to the…
giuffre-maxwell
1320-9
10 pg
…other under-aged
girls). Epstein instructed Jane Doe #3 that she was to give the Prince whatever he demanded and
required Jane Doe #3 to report back to him on the details of the sexual abuse. Maxwell
facilitated Prince Andrew…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.1
13 pg
…The Palm Beach Police Department put together an 87-page report based on
witness interviews and other evidence documenting sexual abuse of dozens of
minor girls occurring in Epstein’s Florida mansion – a location where Ms.
Giuffre said Dershowitz had…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.45
13 pg
…The Palm Beach Police Department put together an 87-page report based on
witness interviews and other evidence documenting sexual abuse of dozens of
minor girls occurring in Epstein’s Florida mansion – a location where Ms.
Giuffre said Dershowitz had…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.3
10 pg
…other under-aged
girls). Epstein instructed Jane Doe #3 that she was to give the Prince whatever he demanded and
required Jane Doe #3 to report back to him on the details of the sexual abuse. Maxwell
facilitated Prince Andrew…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.6
10 pg
…10
sentenced not later than October 26, 2007. The United States has
no
objection to Epstein self-reporting to begin serving his sentence not
later than Janua…
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