…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…
…Courts Substance or procedure; determinativeness Federal courts sitting in diversity apply state Synopsis substantive law and federal procedur…
…hyperbole and indignation cannot change the simple fact that Plaintiff willfully and intentionally set a bonfire and burned her journal that she admits contained information relevant to test the allegations she made in the Crime Victims Right Act Case (“CVRA”)…
… Attached hereto as Exhibit 1, is a true and correct copy of the Government’s September 3, 2008 Victim Notification Letter. 4. Attached hereto as Composite Exhibit 2, is a true and correct copy of flight logs for Jeffrey Epstein…
…s Intentional Destruction of Evidence and further states as follows: INTRODUCTION In 2013, after Plaintiff was in the process of attempting to join the Crime Victims’ Rights Act litigation (“CVRA Litigation”) represented by her current counsel, Plaintiff willfully and deliberately …
… rather, he is trying to find a way to send this victim of sexual trafficking to “jail.” “She was hiding in Colorado…but we found her and she will have to be deposed. The end 1 For the limited…
…the first time on Thursday • They show that former President Bill Clinton boarded the plane with women believed to have been involved in creating underage sex slave ring • Alleged victim Virginia Roberts says she was recruited as a slave when …
…Q. And she was not listed by you as a victim Case 1:15-cv-07433-LAP Document 1199-26 Filed 01/27/21 Page 4 of 4 Page 195 1 JOSEPH RECAREY - CONFIDENTIAL 2 as part of this case…
…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, 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, 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…
…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…
…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…
…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…
…fact. PLAINTIFF’S MISSTATEMENTS OF FACT 1. 1 2. “Ms. Giuffre was the child victim of sexual abuse, which is undisputed.” (Reply at 9) If there is one thing this litigation makes clear, it is heavily disputed that Ms…
…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…
…the CVRA 23 action; the Epstein plea agreement and nonprosecution, and 24 registration; and the victim notification letter. Seems to me 25 all those present same of the same basic problems, and I'll SOUTHERN DISTRICT REPORTERS, P.C. (212…
…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…
…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…
…the CVRA 23 action; the Epstein plea agreement and nonprosecution, and 24 registration; and the victim notification letter. Seems to me 25 all those present same of the same basic problems, and I'll SOUTHERN DISTRICT REPORTERS, P.C. (212…