…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
…The Intervenors’ requests to unseal should be denied. A. Intervenors’ First Proposition of Law: For minor victims of sexual abuse, “redactions should be applied sparingly to shield only information that would identify those who have not already been publicly identified…
…1 is a true and correct copy of September 2, 2008, Victim Notification Letter (GIUFFRE001203-GIUFFRE001205). 4. - Attached hereto as Sealed Exhibit 2 is a true and correct copy of Excerpts of January 16 2016, Deposition of Virg…
…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 …
…Courts Substance or procedure; determinativeness Federal courts sitting in diversity apply state Synopsis substantive law and federal procedur…
…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…
… 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 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…
…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…
…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…
…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<…
…VIRGINIA L. GIUFFRE, Plaintiff, v. 15-cv-07433-RWS ..... GHISLAINE MAXWELL, Defendant. --------------------------------------------------X Declaration of Laur…
…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…
…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…
…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, 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…
…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…
…proposed additional redactions comport with the Court’s direction that Non-Parties be given the opportunity to review and object before any information identifying their identity or any conduct attributed to them (including as either an alleged victim of Mr…
…values.” See Delta Air Lines, 2020 WL 2614704, at *4. Intervenors address the Does’ objections based on the categories under which the Does fall: victims of sexual abuse, on the one hand, and those accused of wrongdoing or who were…
…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…
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