giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
…The Intervenors’ requests to unseal should be denied.
A. Intervenors’ First Proposition of Law: For minor victims of sexual abuse, “redactions
should be applied sparingly to shield only information that would identify those who
have not already been publicly identified…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.5
3 pg
…1 is a true and correct copy of September 2,
2008, Victim Notification Letter (GIUFFRE001203-GIUFFRE001205).
4.
-
Attached hereto as Sealed Exhibit 2 is a true and correct copy of Excerpts of
January 16 2016, Deposition of Virg…
giuffre-maxwell
gov.uscourts.nysd.447706.41.5
18 pg
…ORDER
Upon a showing of good cause in support of the entry of a protective order to protect
the discovery and dissemination of confidential information, including sensitive personal
information relating to a victim of sexual abuse, copyright or trade secrets…
giuffre-maxwell
gov.uscourts.nysd.447706.185.4
10 pg
…concludes that they
should be denied.
I. Background
This is an action by two unnamed petitioners, Jane Doe 1 and Jane Doe 2, seeking to
prosecute a claim under the Crime Victims’ Rights Act (CVRA), 18 U.S.C. § 3771…
giuffre-maxwell
gov.uscourts.nysd.447706.562.1
13 pg
…arises out of Defendant Maxwell’s defamatory statements against
Plaintiff Giuffre. As described below, Giuffre was a victim of sexual trafficking and abuse while
she was a minor child. Defendant Maxwell not only facilitated that sexual abuse but, most
recently…
giuffre-maxwell
gov.uscourts.nysd.447706.1.0
12 pg
…arises out of Defendant Maxwell’s defamatory statements against
Plaintiff Giuffre. As described below, Giuffre was a victim of sexual trafficking and abuse while
she was a minor child. Defendant Maxwell not only facilitated that sexual abuse but, most
recently…
giuffre-maxwell
gov.uscourts.nysd.447706.24.1
13 pg
…arises out of Defendant Maxwell’s defamatory statements against
Plaintiff Giuffre. As described below, Giuffre was a victim of sexual trafficking and abuse while
she was a minor child. Defendant Maxwell not only facilitated that sexual abuse but, most
recently…
giuffre-maxwell
gov.uscourts.nysd.447706.54.0
11 pg
…s
media exposure, to enhance her marketability, to extract financial gain for herself and her family,
and to promote her sham non-profit, Victims Refuse Silence, Inc.
2. No law enforcement agency pursued any criminal charges against Ms. Maxwell,
even…
giuffre-maxwell
gov.uscourts.nysd.447706.40.0
8 pg
…abuse
allegations of a minor child, Ms. Giuffre defined confidential information as:
“including sensitive personal information relating to a victim of sexual abuse,
copyright or trade secrets, commercially sensitive information or proprietary
information.” Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…Giuffre, including two police reports describing Ms. Giuffre as a
fourteen-year-old victim of rape. Other police reports show her to be the victim of other crimes,
including domestic violence. Defendant should not be allowed to make these police…
giuffre-maxwell
gov.uscourts.nysd.447706.1087.0
4 pg
…Maxwell contends that Ms. Giuffre’s “proposed
redactions contain errors which reveal the names of [n]onparties,
including alleged victims.” (Id.) Ms. Giuffre suggests in her
response that any unredacted nonparty names may have already been
released by the Court…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.4
23 pg
…ORDER
Upon a showing of good cause in support of the entry of a protective order to protect
the discovery and dissemination of confidential information, including sensitive personal
information relating to a victim of sexual abuse, copyright or trade secrets…
giuffre-maxwell
gov.uscourts.nysd.447706.542.5
11 pg
…Court concludes that they
should be denied.
I. Background
This is an action by two unnamed petitioners, Jane Doe 1 and Jane Doe 2, seeking to
prosecute a claim under the Crime Victims' Rights Act (CVRA), 18 U. S. C…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.1
13 pg
…criminal
procedure, criminal, and crime victims’ rights.
1
Case 1:15-cv-07433-LAP Document 1330-1 Filed 01/05/24 Page 2 of 13
THE FLORIDA CRIME VICTIMS RIGHTS ACT CASE
4. Since July 2008, I have been…
giuffre-maxwell
gov.uscourts.nysd.447706.363.4
11 pg
…concludes that they
should be denied.
I. Background
This is an action by two unnamed petitioners, Jane Doe 1 and Jane Doe 2, seeking to
prosecute a claim under the Crime Victims’ Rights Act (CVRA), 18 U.S.C. § 3771…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.45
13 pg
…criminal
procedure, criminal, and crime victims’ rights.
1
Case 1:15-cv-07433-LAP Document 1218-45 Filed 07/15/21 Page 2 of 13
THE FLORIDA CRIME VICTIMS RIGHTS ACT CASE
4. Since July 2008, I have been…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.5
11 pg
…concludes that they
should be denied.
I. Background
This is an action by two unnamed petitioners, Jane Doe 1 and Jane Doe 2, seeking to
prosecute a claim under the Crime Victims’ Rights Act (CVRA), 18 U.S.C. § 3771…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…discovery would be
subject to the Protective Order previously issued in this action; (b) persons who are identified as
having allegedly engaged in sexual acts with Plaintiff, or other alleged victims, or allegedly
facilitated such acts; (c) persons whose intimate…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.1
4 pg
…discovery would be subject to the Protective Order previously issued in this action; (b) persons
who are identified as having allegedly engaged in sexual acts with Plaintiff, or other alleged
victims, or allegedly facilitated such acts; (c) persons whose intimate…
giuffre-maxwell
gov.uscourts.nysd.447706.1232.1
7 pg
…discovery would be subject to the Protective Order previously issued in this action; (b) persons
who are identified as having allegedly engaged in sexual acts with Plaintiff, or other alleged
victims, or allegedly facilitated such acts; (c) persons whose intimate…