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.447706.1090.36_1
35 pg
…any) from FBI
records. You need to include as many details as possible so they can focus and narrow the search.
Explain that you are looking for information related to your recovery as a victim of . The
process may take…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…1 and Jane Doe 2, as well as movants Jane Doe
No. 3 and Jane Doe No. 4 (“the victims” 1), to respond in opposition to Mr. Dershowitz’s motio n
for limited intervention (DE 282). Dershowitz moves to intervene…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.5
12 pg
…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”)…
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.447706.509.0
18 pg
…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 …
giuffre-maxwell
gov.uscourts.nysd.447706.1150.3_2
12 pg
…v=ZFefTM1VAow
14 https://nypost.com/tag/ghislaine-maxwell/
15 https://nypost.com/2020/11/03/two-epstein-victims-drop-cases-against-estate-ghislaine-maxwell/
16 https://apnews.com/article/new-york-jeffrey-epstein-ghislaine-maxwell-manhattan-ec7b6b0a07aa51bb7c0147d473535bcb
17 https://www…
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.447706.1199.26_1
4 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…full disclosure, I want to let you know that
16 that's what the protective order currently says.
17 The plaintiff would like to request that names of
18 victims, of individuals who consider themselves to be a victim
19…
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.447706.1059.0
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.447706.1330.7
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.447706.1330.23
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.447706.1326.4
35 pg
…from FBI
records. You need to include as many details as possible so they can focus and narrow the search.
Explain that you are looking for information related to your recovery as a victim of Ron Eppinger. The
process may…
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.447706.1083.0
3 pg
…produced or answered discovery based on the understanding that
such discovery would be subject to the Protective Order, (b) persons who are identified as
allegedly having engaged in sex acts with Plaintiff or other alleged victims, or facilitated such
acts…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.23
10 pg
…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-maxwell
gov.uscourts.nysd.447706.1320.39
35 pg
…from FBI
records. You need to include as many details as possible so they can focus and narrow the search.
Explain that you are looking for information related to your recovery as a victim of Ron Eppinger. The
process may…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…non-
parties is no longer appropriate. Plaintiff respectfully requests that the Parties be permitted to
review and publish the sealed materials subject to redactions to protect the names and personally
identifiable information of victims only, which would greatly expedite the…
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