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.447706.1078.1
8 pg
…said Boies, who listened to the hearing remotely.
‘To mount a ‘blame the victim’ defense, particularly in today’s world and trying
to blame these girls for what happened is so contrary to the evidence, is so
contrary to people…
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.447706.1218.42
9 pg
…2 of 9
CNN
SHOW: New Day 8:30 AM EST
January 6, 2015 Tuesday
TRANSCRIPT: 010606CN.V42
SECTION: NEWS; International
LENGTH: 3114 words
HEADLINE: Plan Crash Survivor's Steps; Celebrities Fight Sex Scandals;
Remembering Mario Cuom…
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.447706.1118.0
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.447706.733.0
3 pg
…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
giuffre-maxwell
gov.uscourts.nysd.447706.1328.22
22 pg
…after
seHvice
1 'I 9.071 (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…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.21
19 pg
…open.
When he got out of school, he ran int
girlfriend and a n o t ~ l a t e r identified as
They all walked to----house where they met and the
victim. - - - s a y s that…
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.447706.385.0
2 pg
…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 …
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.447706.26.0
3 pg
…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…