giuffre-maxwell
gov.uscourts.nysd.447706.1331.32
4 pg
… 1n the summer of 2006, when I was twenty-two years old and living in New York,
I was introduced to Jeffrey Epstein by a girl I had met named Natalya.
Malyshov. Shortly after meeting Jeffrey he invited me to…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.22
22 pg
…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 old, child abuse,
to mobilization, deployment or tactical operati se…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.43
4 pg
…HEADLINE: Prince Andrew under pressure as Palace disputes teen sex scandal
claims
REPORTERS: Philip Williams
BODY:
LEIGH SALES, PRESENTER: It's been a few years since Britain's Royal Family has
been embroiled in a serious scandal, but once again…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.21
19 pg
…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 old, child abuse,
to mobilization, deployment or tactical operati s s…
giuffre-maxwell
gov.uscourts.nysd.447706.590.1
4 pg
…HEADLINE: Prince Andrew under pressure as Palace disputes teen sex scandal
claims
REPORTERS: Philip Williams
BODY:
LEIGH SALES, PRESENTER: It's been a few years since Britain's Royal Family has
been embroiled in a serious scandal, but once again…
giuffre-maxwell
gov.uscourts.nysd.447706.363.0
18 pg
…Emeritus, at Harvard Law School, where I taught
criminal law, legal ethics and other subjects for 50 years. As a criminal defense attorney, I have
also represented numerous individuals accused of crimes over the course of my career. I am…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.9
18 pg
…Emeritus, at Harvard Law School, where I taught
criminal law, legal ethics and other subjects for 50 years. As a criminal defense attorney, I have
also represented numerous individuals accused of crimes over the course of my career. I am…
giuffre-maxwell
gov.uscourts.nysd.447706.54.0
11 pg
…are false. Giuffre’s fantastical claims,
contained in news stories and press-releases masquerading as legal pleadings over the last five
years have been well-crafted with the assistance of high-priced attorneys to facilitate Giuffre’s
media exposure, to…
giuffre-maxwell
gov.uscourts.nysd.447706.605.0
2 pg
…declare:
1. I am over the age of 18 years and am fully competent to make this Declaration.
The facts set forth herein are within my personal knowledge and are true and correct.
2. I am an attorney duly licensed…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
… We have presented
17 those pro hacs to your Honor. This is the first time in my
18 years of practice that I've had a contested one, so I've looked
19 at the case law surrounding that and…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.1
8 pg
…unwarranted and prejudicial
pretrial publicity by the Government, its agents, and lawyers for alleged witnesses.
Legal Standard
More than fifty years ago, warning of the danger of pretrial publicity to fair trials, the
Supreme Court directed trial judges to take…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…her lack of credibility, her failures of memory and her selective use of law
enforcement. Regarding the year 2015, the police reports demonstrate Plaintiff’s tumultuous
home life, bearing no relationship to any press statements or alleged defamation and providing…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.8
9 pg
…For example, Defendant swore under oath that she hardly was around Jeffrey Epstein for more
than “maybe an hour or two” in the years after 2003 until she claimed she ultimately left his
employment in 2008 or 2009. See Pottinger…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.26
5 pg
…these underage girls
18 were visiting Jeffrey's home?
19 MR. PAGLIUCA: Objection to the
20 form and foundation.
21 A. I was not -- what year, I need
22 years.
23 Q. How about let's say 2005?
24 A…
giuffre-maxwell
gov.uscourts.nysd.447706.1264.0
1 pg
…1157, 1230. That protocol, which was first put in place more than two years ago, balances
the presumption of public access to judicial documents against the privacy, reputational, and
other countervailing interests that support the continued sealing of certain of…
giuffre-maxwell
gov.uscourts.nysd.447706.751.12
3 pg
…as two of the men she was made to 'service'.
But those who used to be close to the 31-year-old say she relished her role as his 'travelling masseuse' and never
acted like she was being held captive.
…
giuffre-maxwell
gov.uscourts.nysd.447706.751.10
4 pg
…3 beginning in
approximately early 2001. Jane Doe No. 3 was then 17 years old."
The letter includes a picture of the woman and Andrew which was taken around that time, they say. The lawyers also
want to discuss subsequent…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.22_1
12 pg
…6 Q. How old was this girl?
7 A. 15 years old.
8 Q. What happens next when Ghislaine
9 Maxwell and Jeffrey Epstein and a 15-year-old
10 girl walk into Eva Anderson's home?
11 MR. PAGLIUCA…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…wants to
publicize police reports concerning Ms. Giuffre - most of them from when she was a child, some
of them concerning her being raped when only 14 years. Defendant’s challenge to Ms. Giuffre’s
confidentiality designation is without merit…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…Filed Docket
on FLSD 01/03/24 Page 3 of Page
12/30/2014 10 2 of 13
FACTUAL BACKGROUND
As the Court is aware, more than six years ago, Jane Doe #1 filed the present action…