…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…
…days after service C 11 ~W71 (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…
…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…
…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…
…concludes that they should be denied. I. Background This is an action by two unnamed petitioners, Jane Doe 1 and Jane Doe 2, seeking to prosecute a claim under the Crime Victims’ Rights Act (CVRA), 18 U.S.C. § 3771…
…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…
…arises out of Defendant Maxwell’s defamatory statements against Plaintiff Giuffre. As described below, Giuffre was a victim of sexual trafficking and abuse while she was a minor child. Defendant Maxwell not only facilitated that sexual abuse but, most recently…
…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…
…arises out of Defendant Maxwell’s defamatory statements against Plaintiff Giuffre. As described below, Giuffre was a victim of sexual trafficking and abuse while she was a minor child. Defendant Maxwell not only facilitated that sexual abuse but, most recently…
…arises out of Defendant Maxwell’s defamatory statements against Plaintiff Giuffre. As described below, Giuffre was a victim of sexual trafficking and abuse while she was a minor child. Defendant Maxwell not only facilitated that sexual abuse but, most recently…
…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”)…
…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…
…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…
…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 …
…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…
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