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.447706.1090.36_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.447706.1326.4
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.447706.1320.39
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
1320-39
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.447706.1122.0_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.447706.1113.0
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.447706.41.5
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.447706.21.0
4 pg
… 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…
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.447706.1199.26_1
4 pg
…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-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.447706.824.0_2
47 pg
…full disclosure, I want to let you know that
16 that's what the protective order currently says.
17 The plaintiff would like to request that names of
18 victims, of individuals who consider themselves to be a victim
19…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.2
26 pg
…1 JOSEPH RECAREY - CONFIDENTIAL
2 BY MR. PAGLIUCA:
3 Q. Then there's a category, victim
4 information, and then we have listed, I believe, a
5 total of 17 individuals that the Palm Beach Police
6 Department incident report…
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.447706.1330.7
18 pg
…1 JOSEPH RECAREY - CONFIDENTIAL
2 BY MR. PAGLIUCA:
3 Q. Then there's a category, victim
4 information, and then we have listed, I believe, a
5 total of 17 individuals that the Palm Beach Police
6 Department incident report…