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.447706.1328.22
22 pg
…after
seHvice
1 'I 9.071 (2)(d) Surveillance t niques, procedures, an (2)(h)(1) Identity of victim of sexual battery, lewd and
inventory of law enforcement resources, policies or ascivious offense upon a person less than 16 years…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…29/20 Page 6 of 161
Socialite Ghislaine Maxwell 'groped a 16-year-old girl
during a naked massage,' victims' lawyer says
dailymail.co.uk/news/article-8163681/Socialite-Ghislaine-Maxwell-groped-16-year-old-girl-naked-massage-victims-
lawyer…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…and JANE DOE #2
v.
UNITED STATES
__________________________/
JANE DOE #3 AND JANE DOE #4’S MOTION PURSUANT TO RULE 21 FOR
JOINDER IN ACTION
COME NOW Jane Doe #3 and Jane Doe #4 (also referred to as “the new victims”)…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.14
6 pg
…known as "Orgy lsland," have included Bill Cllnton, Prince Andrew and Stephen Hawking.
According to a 2011 court fillng by alleged Epstein victim Virginia Roberts Giuffre, she saw Clinton and Prince Andrew on the island but
never saw the former…
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.447706.542.8
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.447706.1328.44
14 pg
…that somebocly thnt was n sexual abuse 7 been at the house when E.W. was in Jeffrey
8 victim at one point in time or Jeffrey Epstein 8 Epstein's bedroom getting sexually nlJused,
9 and Jean Luc Brunel? …
giuffre-maxwell
gov.uscourts.nysd.447706.1328.2
26 pg
…1 JOSEPH RECAREY - CONFIDENTIAL
2 BY MR. PAGLIUCA:
3 Q. Then there's a category, victim
4 information, and then we have listed, I believe, a
5 total of 17 individuals that the Palm Beach Police
6 Department incident report…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.7
18 pg
…1 JOSEPH RECAREY - CONFIDENTIAL
2 BY MR. PAGLIUCA:
3 Q. Then there's a category, victim
4 information, and then we have listed, I believe, a
5 total of 17 individuals that the Palm Beach Police
6 Department incident report…
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.447706.828.0
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.447706.1094.0
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.447706.1218.24
4 pg
…selling these
false stories now for money about me. That is a form of prostitution."
"Do you have any concern calling her a prostitute when she was victimized at such an early age by a wealthy
man?" Norman asked.
"She…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.6
10 pg
…recall.” For example, when
faced with the police report which contains statements from approximately thirty (30) different
victims during a time frame which the Defendant acknowledges she was actively working for
Epstein at his various homes, Defendant challenged the veracity…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.10_2
10 pg
…recall.” For example, when
faced with the police report which contains statements from approximately thirty (30) different
victims during a time frame which the Defendant acknowledges she was actively working for
Epstein at his various homes, Defendant challenged the veracity…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.30
4 pg
…selling these
false stories now for money about me. That is a form of prostitution."
"Do you have any concern calling her a prostitute when she was victimized at such an early age by a wealthy
man?" Norman asked.
"She…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.16
22 pg
…discovered.
13. Defendant Epstein displays his enormous wealth,Inwer and influence
to his employees; to the victims procured for sexual purposes; and to the public in
order to advance and carry out his crimes and torts. At all relevant times…
giuffre-maxwell
1320-6
10 pg
…recall.” For example, when
faced with the police report which contains statements from approximately thirty (30) different
victims during a time frame which the Defendant acknowledges she was actively working for
Epstein at his various homes, Defendant challenged the veracity…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.41
4 pg
…selling these
false stories now for money about me. That is a form of prostitution."
"Do you have any concern calling her a prostitute when she was victimized at such an early age by a wealthy
man?" Norman asked.
"She…
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