giuffre-maxwell
gov.uscourts.nysd.447706.733.0
3 pg
…Virginia L. 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
VICTIM
giuffre-maxwell
gov.uscourts.nysd.447706.385.0
2 pg
…representing
. Although Ms. Giuffre is not a
, central to that action are her allegations that she was the
victim of “sexual trafficking.”
4. Based on my knowledge of the …
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.447706.1094.2_2
15 pg
…York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S
MOTION IN LIMINE TO EXCLUDE REFERENCES TO
“CRIME VICTIM<…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.23
9 pg
…Ms. Giuffre has alleged that Defendant defamed her when she
called her a liar after Ms. Giuffre spoke out about being a child victim of sex abuse at the hands of
Defendant and Defendant’s long-time boyfriend, convicted pedophile…
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.447706.36.0
4 pg
… Attached hereto as Composite Exhibit 7, is a true and correct copy of the
September 9, 2008 Victim Notification Letter.
10. Attached hereto as Composite Exhibit 8, is a true and correct copy of the Notice
of Deposition of Ghislaine…
giuffre-maxwell
gov.uscourts.nysd.447706.828.0
3 pg
…a true and correct copy of Paul G. Cassel,
Esq.’s Curriculum Viate.
4. Attached hereto as Sealed Exhibit 2 is a true and correct copy of the July 20, 2010
Victim Notification Letter addressed to Farmer, Jaffe, Weissing, Edwards…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.17
6 pg
…most are not common words (more on that below).
Per our conversation, there are a number of individuals who we have reason to believe were either:
(1) victims of the “massages;”
(2) witnesses the “massages” (including people who have knowledge…
giuffre-maxwell
gov.uscourts.nysd.447706.1094.0
40 pg
…York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S
MOTION IN LIMINE TO EXCLUDE REFERENCES TO
“CRIME VICTIM<…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.40
3 pg
…than the world to know all about the inequality of the government to act
appropriately and violate our rights as victims by giving Jeffrey Epstein a plea lxirgain and immunity to only take accreditation for one account of the
sensi…
giuffre-maxwell
gov.uscourts.nysd.447706.1313.0
1 pg
…and the Miami Herald’s consent to such redactions is based on circumstances
specific to Doe 107 and does not extend to other purported victims living in countries without the
same risks of physical harm.
The Parties therefore respectfully request…
giuffre-maxwell
gov.uscourts.nysd.447706.724.0
7 pg
…many if not all of the Complaints against Epstein pursuant to his plea agreement
to fund such lawsuits against him were styled as “Jane Doe” to protect the privacy of his
underage victims.
1
Case 1:15-cv-07433-LAP…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…in that they seek to invade her privacy for the sole
purpose of harassing and intimidating Ms. Giuffre who was a victim of sexual trafficking. Ms.
Giuffre objects to the requests to the extent they are overly broad and unduly…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…Ransome available to Defendant for a deposition. After first
delaying in taking that deposition, Defendant then made this victim of sex trafficking, who had flown
to the United States from Barcelona, sit for ten hours at a deposition and be…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.9
29 pg
…Ransome available to Defendant for a deposition. After first
delaying in taking that deposition, Defendant then made this victim of sex trafficking, who had flown
to the United States from Barcelona, sit for ten hours at a deposition and be…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…in that they seek to invade her privacy for the sole
purpose of harassing and intimidating Ms. Giuffre who was a victim of sexual trafficking. Ms.
Giuffre objects to the requests to the extent they are overly broad and unduly…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…had been to the house appJoxima-el 4 . or 5 times in
the past year. She accompanied Robson withl I
I 3 • • • • · • • • the 14-year-old victim, and .
Eacn time the girls were taken over, they were previously told they
…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…in that they seek to invade her privacy for the sole
purpose of harassing and intimidating Ms. Giuffre who was a victim of sexual trafficking. Ms.
Giuffre objects to the requests to the extent they are overly broad and unduly…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
45 pg
…had been to the house appJoxima-el 4 . or 5 times in
the past year. She accompanied Robson withl I
I 3 • • • • · • • • the 14-year-old victim, and .
Eacn time the girls were taken over, they were previously told they
…
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