giuffre-maxwell
gov.uscourts.nysd.447706.1295.14
6 pg
…was also a pedophile, accused of recruiting dozens of underage girls into a sex-slave network, buying their
silence and moving along, although he has been convicted of only one count of soliciting prostitution from a minor. Visitors to his…
giuffre-maxwell
gov.uscourts.nysd.447706.542.8
4 pg
…INCORPORATION
In compliance with Chapter 617, F. S., ( Not for Profit)
ARTICIS I NAME
The name of the cQrporation shall be:
Victims Refuse Silence, Inc.
I
ARTICLE H PRINCIPAL OFFICE
Principal…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.4
4 pg
…statements to the press,
in court pleadings, and in sworn testimony at issue in this matter. Mr. Edwards
also has knowledge concerning "Victim's Refuse Silence, Inc."
7. Jeffrey Epstein
c/o Tonja Haddad Coleman, Esq.
315 SE 7th Street…
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…early 2011.
o Paul Cassell and Brad Edwards (along with other Farmer, Jaffe, attorneys)
represented Ms. Giuffre and Victims Refuse Silence, giving advice regarding
Victims Refuse Silence, starting in October, 2014.
o Meg Garvin (law professor at Lewis & Clark Law…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…has rounded on her accusers, insisting that her portrayal as a
‘cartoon caricature of a villain’ is utterly false
Breaking a year-long silence since Epstein’s death, sources close to Maxwell have gone on
the offensive to put her…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.24
16 pg
…11) Ms. Boylan; and (12) the 30(b)(6) witness for Victims Refuse
Silence.
7
Defendant has unilaterally scheduled - without consulting counsel for Ms. Giuffre - at least two
of these depositions for days when depositions of Ms. Giuffre’s witnesses…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…early 2011.
o Paul Cassell and Brad Edwards (along with other Farmer, Jaffe, attorneys)
represented Ms. Giuffre and Victims Refuse Silence, giving advice regarding
Victims Refuse Silence, starting in October, 2014.
o Meg Garvin (law professor at Lewis & Clark Law…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.3
26 pg
…Broward County, Florida, attached
hereto as Exhibit 18.
19. Victims Refuse Silence Articles of Incorporation and Amendment, attached hereto
as Composite Exhibit 19.
20. Victims Refuse Silence By-laws, attached hereto as Exhibit 20.
20
…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…the individual names of Hilary’s
Special Agent Officers involved in intimidating her. She was then forced against her will to sign a
legally binding confidentially agreement on Hilary’s behalf for her eternal silence. If she breaks this
agreement…
giuffre-maxwell
1320-37
48 pg
…early 2011.
o Paul Cassell and Brad Edwards (along with other Farmer, Jaffe, attorneys)
represented Ms. Giuffre and Victims Refuse Silence, giving advice regarding
Victims Refuse Silence, starting in October, 2014.
o Meg Garvin (law professor at Lewis & Clark Law…
giuffre-maxwell
1320-24
16 pg
…11) Ms. Boylan; and (12) the 30(b)(6) witness for Victims Refuse
Silence.
7
Defendant has unilaterally scheduled - without consulting counsel for Ms. Giuffre - at least two
of these depositions for days when depositions of Ms. Giuffre’s witnesses…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…early 2011.
o Paul Cassell and Brad Edwards (along with other Farmer, Jaffe, attorneys)
represented Ms. Giuffre and Victims Refuse Silence, giving advice regarding
Victims Refuse Silence, starting in October, 2014.
o Meg Garvin (law professor at Lewis & Clark Law…