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.447706.26.1
26 pg
…Courts
Substance or procedure; determinativeness
Federal courts sitting in diversity apply state
Synopsis
substantive law and federal procedur…
giuffre-maxwell
gov.uscourts.nysd.447706.26.0
3 pg
…Cosby”) (attached as Exhibit A).
In Cosby, the court denied Bill Cosby’s motion to dismiss the sexual assault victim’s
defamation complaint, holding that Cosby’s “suggestion that Plaintiff intentionally lied about
being sexually assaulted” could expose plaintiff to…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.28_4
5 pg
…5
due to.. VR ..lack of credibility "
The new interest in this old settled case results from lawyers representing
some of JE victims filed a suit against the US government not JE . They
contend that the Us govt violated their…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.14
3 pg
…and Paul G. Cassell to
represent me on legal matters, including a Crime Victims’ Rights Act (CVRA) action then
pending in Florida court in Florida. They have represented me (along with other attorneys)
continuously since then.
3. I have had…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…Edwards and Cassell do acknowledge that the public filing in the Crime Victims’
Rights Act case of their client’s allegations against Defendant Dershowitz became a major
distraction from the merits of the well-founded Crime Victims’ Rights Act case…
giuffre-maxwell
gov.uscourts.nysd.447706.1059.0
3 pg
…brought on plowed ground. In October 2017 third parties sued by
an alleged Epstein victim moved to modify the Protective Order to permit them to “use all
evidence” produced by a non-party witness in this case. Doc.924 (filed…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.4_1
4 pg
…Other materials you produced include police records concerning my client while she
was a minor child, and police records showing my client as a victim of domestic abuse, which
include descriptions of her minor children.
As far as my good…
giuffre-maxwell
gov.uscourts.nysd.447706.89.0
10 pg
…part of her
legal team. Since returning to full time law teaching in 2007, Professor Cassell has developed a
specialized expertise in crime victims’ rights, an area in which he has co-written a leading law
school casebook. See Beloof…
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.447706.201.0
5 pg
…Giuffre has fittingly marked her Rule 26 Disclosures as confidential. The designation is
made in good faith to protect these individuals and their privacy, who are victims of sexual abuse
(or, alternatively, witnesses with information about sexual abuse).
Federal Rule…
giuffre-maxwell
gov.uscourts.nysd.447706.23.0
32 pg
…Thus Defeating Any Privilege.. .................................9
2. Calling A Sexual Abuse Victim A “Liar” Is More Than
A “General Denial” And Qualifies As Defamation.............................10
3. Defendant’s Cited Cases Do Not Su…
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.447706.29.0
2 pg
…among other things, that Cosby defamed an alleged sexual
assault victim by issuing statements to the press describing the allegations against him as
“unsubstantiated, fantastical stories…[that] have escalated far past the point of absurdity.” (Ex.
A at 8…
giuffre-maxwell
gov.uscourts.nysd.447706.408.0
13 pg
…where I teach criminal
procedure, criminal, and crime victims’ rights.
1
THE FLORIDA CRIME VICTIMS RIGHTS ACT CASE
4. Since July 2008, I have been involved in important and precedent-setting crime
victims’ rights litigation in the Southern District…
giuffre-maxwell
gov.uscourts.nysd.447706.811.0
2 pg
…pictures, hospital records, time & travel
records, victim notification letters, and a black book. This reference to evidence is
otherwise discussed in publicly available articles and even the public docket entries in
this case.
Similarly, her arguments over the press release…
giuffre-maxwell
gov.uscourts.nysd.447706.944.0
11 pg
…a series of salacious and
provocative allegations gratuitous to her defamation claim. She alleged she was the “victim of
sexual trafficking and abuse while she was a minor child” and that Ms. Maxwell “facilitated”
plaintiff’s sexual abuse and “wrongfully…
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.447706.1074.5
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…
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