giuffre-maxwell
gov.uscourts.nysd.447706.1122.0_2
13 pg
…related to victims would allow
the USVI to avoid re-deposing witnesses whose testimony may not be relevant to Epstein’s
alleged crimes in the Virgin Islands, or re-taking testimony where it is sufficient. This avoids
subjecting survivors to…
giuffre-maxwell
gov.uscourts.nysd.447706.1118.0
21 pg
…nonparties—particularly nonparties who are alleged victims of Jeffrey
Epstein’s sexual abuse—weighs heavily against the unilateral disclosure
that (the intervenor) seeks. Those interests are particularly acute given that
the psychological and emotional wellbeing o…
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.447706.26.1
26 pg
…Courts
Substance or procedure; determinativeness
Federal courts sitting in diversity apply state
Synopsis
substantive law and federal procedur…
giuffre-maxwell
gov.uscourts.nysd.447706.363.6
15 pg
… 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…
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.447706.1250.0
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.447706.1059.0
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.447706.1199.4_1
4 pg
…v. Maxwell
Case No. 15-cv-07433-RWS
Dear Jeffrey:
You have stated that there is "likely" no good faith basis for keeping the details of the
rape of a 14 year old girl, and the reactions of Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
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.447706.89.0
10 pg
…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…
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.447706.23.0
32 pg
…Ms. Giuffre sought to
join a long-running Crime Victims’ Rights Act (“CVRA”) lawsuit, which was brought by other
young girls who were also abused, and sought to challenge Jeffrey Epstein’s non-prosecution
agreement which also pardoned co-conspirators…
giuffre-maxwell
gov.uscourts.nysd.447706.29.0
2 pg
…among other things, that Cosby defamed an alleged sexual
assault victim by issuing statements to the press describing the allegations against him as
“unsubstantiated, fantastical stories…[that] have escalated far past the point of absurdity.” (Ex.
A at 8…
giuffre-maxwell
gov.uscourts.nysd.447706.408.0
13 pg
…Crime Victims’ Rights Act (CVRA), 18 U.S.C. § 3771. Along with Florida
co-counsel Bradley J. Edwards, I have been pursuing a federal case pro bono on behalf of two
young women who were sexually abused as underage girls…
giuffre-maxwell
gov.uscourts.nysd.447706.811.0
2 pg
…pictures, hospital records, time & travel
records, victim notification letters, and a black book. This reference to evidence is
otherwise discussed in publicly available articles and even the public docket entries in
this case.
Similarly, her arguments over the press release…
giuffre-maxwell
gov.uscourts.nysd.447706.944.0
11 pg
…a series of salacious and
provocative allegations gratuitous to her defamation claim. She alleged she was the “victim of
sexual trafficking and abuse while she was a minor child” and that Ms. Maxwell “facilitated”
plaintiff’s sexual abuse and “wrongfully…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…became a major
distraction from the merits of the wellfounded Crime Victims’ Rights Act case” challenging the
deal federal prosecutors struck with one of Dershowitz’s former clients, financier Jeffrey
Epstein. (Accused of having sexual relations with multiple underage girls…
giuffre-maxwell
gov.uscourts.nysd.447706.1100.1
13 pg
…15-cv-07433-LAP
1:20-cr-00330-AJNDocument
Document1100-1
36 Filed
Filed
07/30/20
08/10/20Page
…