giuffre-maxwell
gov.uscourts.nysd.447706.1090.36_1
35 pg
…of Sharon Rikard
To: Virginia Giuffre
Subject: Re: Victims Refuse Silence
Date: Saturday, March 28, 2015 9:49:55 AM
Hi Virginia,
So sorry for the late response. Our organization currently works with survivors of
sex trafficking provided continuing education…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…interview, I told her I was fighting not just for myself, but for every Epstein victim. ‘I’m
not going to stop’ I said, ‘until all these girls get justice.’”6
Ms. Maxwell’s Position: As a threshold matter, Ms…
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.447706.1199.1_1
13 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.447706.1199.16_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.447706.1199.4_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.447706.1135.0_6
1 pg
…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…
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.447706.849.0
94 pg
…the CVRA
23 action; the Epstein plea agreement and nonprosecution, and
24 registration; and the victim notification letter. Seems to me
25 all those present same of the same basic problems, and I'll
SOUTHERN DISTRICT REPORTERS, P.C.
(212…
giuffre-maxwell
gov.uscourts.nysd.447706.847.0
94 pg
…the CVRA
23 action; the Epstein plea agreement and nonprosecution, and
24 registration; and the victim notification letter. Seems to me
25 all those present same of the same basic problems, and I'll
SOUTHERN DISTRICT REPORTERS, P.C.
(212…
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.447706.1328.20
14 pg
…Ex. D (GM00780-782).
Plaintiff was not a claimed victim of this crime.
x August 3, 2001 – Plaintiff (then a week shy of her 18th birthday) called police
regarding a theft of cash from her shirt pocket in her apartment…
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.447706.1284.0
17 pg
…C.
(212) 805-0300
MBIMGUIC
Case 1:15-cv-07433-LAP Document 1284 Filed 12/02/22 Page 6 of 17 6
1 identity should be sealed because she was a victim of serious
2 abuse by Jeffrey Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1283.0
17 pg
…C.
(212) 805-0300
MBIMGUIC
Case 1:15-cv-07433-LAP Document 1283 Filed 12/02/22 Page 6 of 17 6
1 identity should be sealed because she was a victim of serious
2 abuse by Jeffrey Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…that, “after the Maxwell criminal
trial also is concluded,” all remaining Non-Parties could be divided into four “categories” ((i)
Epstein employee, (ii) Epstein affiliate, (iii) victim, etc.) so that they can be addressed in groups.
Such an approach, however…
giuffre-maxwell
gov.uscourts.nysd.447706.1248.0
6 pg
…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…
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…