giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…The USVI alleges in its CICO action
that decedent Jeffrey E. Epstein engaged in a criminal sexual trafficking enterprise in the Virgin
Islands, wherein he used his vast wealth and property holdings and a deliberately opaque web of
corporations and…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.17
13 pg
…of Confidential Materials. This
Court should issue an Order to Show Cause.
FACTUAL BACKGROUND
Ms. Giuffre sought to convert her defamation action into a lawsuit for child “sexual
abuse” and “sexual trafficking” of children. Toward that end, she made numerous…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.15
11 pg
…U.S.C. § 1595 for engaging in commercial sex trafficking. Despite the fact that it is well settled
that a Court should not consider documents beyond the four corners of the complaint in
evaluating a Motion to Dismiss, the Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.96.0
15 pg
… Documents Evidencing Communications and Interactions With
Co-Conspirators.............................................................................................................3
B. Documents Concerning Sexual Abuse And Trafficking Of Females............................4
III. ARGUMENT – FORE…
giuffre-maxwell
gov.uscourts.nysd.447706.149.0
9 pg
…i.e., did Ms. Maxwell assist Mr. Epstein in the sexual trafficking of the
Plaintiff from 1999 to 2002. The
ARGUMENT
Federal Rule of Civil Procedure 26(b)(1) provides, in relevant part, that "[p]arties may
obtain discovery regarding…
giuffre-maxwell
gov.uscourts.nysd.447706.201.0
5 pg
…has filed this
motion to protect the Rule 26 Disclosures as confidential.
ARGUMENT
As the Court knows, this case involves such highly sensitive topics as sexual abuse of
females and sexual trafficking of these females. In accordance with Rule 26…
giuffre-maxwell
gov.uscourts.nysd.447706.604.0
11 pg
…N.Y.
Jan. 26, 2017) (complaint). Maxwell has now been accused of running or being involved in a
child sex trafficking ring in multiple lawsuits. Maxwell’s involvement in sex trafficking is
newsworthy on its face. Indeed, the Daily Mail…
giuffre-maxwell
gov.uscourts.nysd.447706.811.0
2 pg
…No. 793
Page 2 of 2
Although Plaintiff’s counsel, in her arguments, made reference to allegedly confidential
evidence of sexual trafficking, she knowingly did so in the presence of undersigned
counsel. Moreover, her arguments were sufficiently vague in detail…
giuffre-maxwell
gov.uscourts.nysd.447706.981.0
2 pg
…the
great travesty of the Epstein criminal case was ignored. See
https://www.politico.com/story/2017/05/04/jeffrey-epstein-trump-lawsuit-sex-trafficking-
237983. Google Trends shows that there was almost no organic interest from the public
in…
giuffre-maxwell
gov.uscourts.nysd.447706.1002.0
2 pg
…ties to Jeffrey Epstein,
go to the media, make false allegations that that person participated in
Mr. Epstein’s “sex trafficking ring,” wait for the public denial, and then sue
for “defamation.” So we agree with Mr. Dershowitz that Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.957.0
13 pg
…of Confidential Materials. This
Court should issue an Order to Show Cause.
FACTUAL BACKGROUND
Ms. Giuffre sought to convert her defamation action into a lawsuit for child “sexual
abuse” and “sexual trafficking” of children. Toward that end, she made numerous…
giuffre-maxwell
gov.uscourts.nysd.447706.944.0
11 pg
…Miami
Herald claims to practice. Indeed none of the descriptions of alleged sexual activities or
unsupported claims of sex with nonparties would be relevant to the Herald’s claimed
investigation of a “cross-border sex-trafficking ring,” Mot. to Unseal…
giuffre-maxwell
gov.uscourts.nysd.447706.1214.0
7 pg
…unsealed.
As set forth in Intervenors’ prior responses, any privacy rights Ms. Maxwell may have are
far outweighed by the public interest in allegations of sexual trafficking of minors, Ms. Maxwell’s
reliance on the protective order was not reasonable…
giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…Motions in limine re admissibility of evidence and related orders.
We said papers in this category were negligibly judicial documents because of plaintiff’s
improper attempt to transform her defamation lawsuit into a de facto sex trafficking lawsuit
against Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…UNSEALING OF SEALED DOCUMENTS
A Federal Court authorized this notice. This is not a solicitation from a lawyer.
This case involves allegations of sexual abuse and sexual trafficking of minors. Some
documents submitted to the Court were filed under seal…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…Epstein would be a key witness in her support, exonerating her
from Plaintiff’s allegations regarding sex abuse, sexual trafficking and acting as his
“madam” to the stars. As proof, one need look no further than emails already reviewed
by…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
… 6, 52, and, in essence, that anyone setting foot in any Epstein’s
residences, including Dershowitz, was or should have been aware Epstein was engaged in the sex
trafficking of minors. See id. at ¶¶ 61-63, 71. Dershowitz is entitled…
giuffre-maxwell
gov.uscourts.nysd.447706.1069.0
25 pg
… Paragraph 53, she accuses Professor
18 Dershowitz of being in a conspiracy with Ms. Maxwell and
19 Jeffrey Epstein in order to conceal their sex trafficking
20 organization. In light of those allegations, and in light of
21 the testimony…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…against British socialite Ghislaine
Maxwell for saying that Roberts made “obvious lies” when accusing Maxwell of recruiting Roberts to
become a victim of sex trafficking between 1999 to 2002.
“Alan Dershowitz is not a party to that litigation,” said Boies…
giuffre-maxwell
gov.uscourts.nysd.447706.1071.0
13 pg
…Case 1:15-cv-07433-LAP Document 1071 Filed 07/01/20 Page 9 of 13
alleged that Ms. Maxwell was a ringleader in Jeffrey Epstein’s
sex-trafficking scheme, a trusted lieutenant of Epstein’s who
facilitated his purported …
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