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Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 30 of 50
performed. Accordingly, any documentation of sexual assault is necessarily akin to a medical
record, and, therefore, precluded under the Court’s April 21, 2016 Order.
5. Information Sought in Interrogatory No. 14 related to Ms. Giuffre’s
Sexual Abuse is Protected by Florida Statutes
Finally, this abuse took place in Florida, and information relating to those events is
protected from disclosure by law. Florida statutes protect “[a]ny information in a videotaped
statement of a minor who is alleged to be or who is a victim of sexual battery . . . which reveals
that minor’s identity.” Fla. Stat. § 119.071. Additionally, Fla. Stat. § 985.036 protects records
where a juvenile is a victim of a crime. Further, Fla. Stat § 794.026 creates a civil right of action
against an individual who communicates to others, identifying information concerning the victim
of a sexual offense. Additionally, Second, Fla. Stat. § 985.04 and Fla. Stat. § 985.054 make
juvenile law enforcement records confidential from members of the public, and states that
information obtained by a law enforcement agent participating in the assessment of a juvenile is
confidential. Finally, certain of the police reports implicate Ms. Giuffre’s involvement with the
Florida Department of Children and Families, see e.g., GM_00750, and if such reports are part of
the State’s Department of Children and Families’ records, they are confidential pursuant to Fla.
Stat. § 39.202(6).
While Defendant, a sex abuser of minors, says that the Protective Order is all the privacy
Ms. Giuffre needs regarding being raped as a 14 year old, Federal Rules of Civil Procedure,
Federal Rules of Evidence, Florida statutes, and case law say otherwise. Indeed, Defendant is
engaging in double-speak on the Protective Order: her joint defense partner Alan Dershowitz is
attempting, through his baseless motion to intervene, to challenge the confidential designations
of various documents in the case, and strip away the Protective Order’s protections. Finally,
Defendant incorrectly states “[n]Jone of this illegal or inappropriate sexual contact, conduct or
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Dates
Document Details
| Filename | Giuffre_Maxwell_Batch4_p00333.png |
| File Size | 302.2 KB |
| OCR Confidence | 94.8% |
| Has Readable Text | Yes |
| Text Length | 2,189 characters |
| Indexed | 2026-02-04 12:41:56.952204 |