giuffre-maxwell
gov.uscourts.nysd.447706.562.1
13 pg
…pertinent part, the Jane Doe No. 102 complaint described in detail how
Maxwell recruited Giuffre (who was then a minor girl) to become a victim of sex trafficking by
introducing Giuffre to Jeffrey Epstein. With the assistance of Maxwell, Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1.0
12 pg
…pertinent part, the Jane Doe No. 102 complaint described in detail how
Maxwell recruited Giuffre (who was then a minor girl) to become a victim of sex trafficking by
introducing Giuffre to Jeffrey Epstein. With the assistance of Maxwell, Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.24.1
13 pg
…pertinent part, the Jane Doe No. 102 complaint described in detail how
Maxwell recruited Giuffre (who was then a minor girl) to become a victim of sex trafficking by
introducing Giuffre to Jeffrey Epstein. With the assistance of Maxwell, Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1113.0
7 pg
…nonparties who are
alleged victims of Jeffrey Epstein’s sexual abuse--weighs heavily
against the unilateral disclosure that Mr. Dershowitz seeks. Those
interests are particularly acute given that the psychological and
emotional wellbeing of survivors of alleged sexual assaults may…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.5
3 pg
…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…
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.447706.40.0
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.447706.1199.16_1
12 pg
…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-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
…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…
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.447706.1320.18
40 pg
…........................................................................................................30
Zois v. Cooper,
268 B.R. 890 (S.D.N.Y. 2001)................................................................................................................17
Statutes
18 U.S.C. § 3771(a)(9)..........................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1353.0
6 pg
…well,” Act § 2(a)(1)–(2), the Act requires the Government to publish the Materials subject to ap-
propriate redactions regarding victim-identifying information.
However, the Materials are subject to both (1) a protective order in this case (Dkt. 62)…
giuffre-maxwell
gov.uscourts.nysd.447706.1021.0
18 pg
… I
14 would think you would give me this much material. You know,
15 this document implicates this person's privacy interests
16 because she is said to be a victim of sex trafficking. That's
17 all you need…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.0
18 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1087.0
4 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.185.4
10 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.946.0_1
14 pg
…larger sex-trafficking
organization. Serious questions remain as to whether the Epstein case was disposed of
appropriately, whether victims were treated properly, and whether Epstein was given favorable
treatment because of his wealth and status. The Miami Herald seeks to…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.14_2
40 pg
…2012) ........................................................................................................ 30
Zois v. Cooper,
268 B.R. 890 (S.D.N.Y. 2001) ................................................................................................................ 17
Statutes
18 U.S.C. § 3771(a)(9) ........................................…
giuffre-maxwell
gov.uscourts.nysd.447706.139.0
7 pg
…course, if Defendant could not
obtain the same information from the law enforcement agency itself, the Defendant should not be
permitted to make an “end run” around that prohibition by seeking the same information from the
crime victim herself. Therefore…
giuffre-maxwell
gov.uscourts.nysd.447706.1028.0
5 pg
…or her name disclosed to the public, e.g., a crime
victim.
Plaintiff and Ms. Maxwell have a fundamental difference in the approach to
identifying the non-parties who should be on the list. Plaintiff takes the position that
if…