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Case 1:15-cv-07433-LAP Document 1328-20 Filed 01/05/24 Page 10 of 14 Colorado Statutes Plaintiff also cites Colorado statutes which, she claims, support the proposition that her identity as the victim of domestic violence is protected by Colorado law. It is not. Section 13- 90-107(k),° is a testimonial privilege statute, not a document-confidentiality statute. That provision forbids a victim’s advocate from being required to testify concerning any communications with an alleged victim of domestic violence or assault. No one has sought testimony from any victim’s advocate in these proceedings. The Colorado documents also do not contain Plaintiff's communications to any victim’s advocate. Menninger Decl., Ex. H. Plaintiff also cites Colorado Rev. Stat. § 19-1-301 and 302 for the proposition that the identities of her children cannot be disclosed. Those provisions maintain the confidentiality of records pertaining to juvenile justice actions against children. The documents at issue do not relate to any such action; the children were witnesses to an alleged crime committed by Plaintiff's husband against her, not the subjects of any criminal action themselves. Cc. All Documents Were Redacted Appropriately By the Law Enforcement Agencies The police reports from Florida that pertain to juveniles who are alleged victims of criminal sexual conduct (as opposed to Plaintiff's own criminal conduct as an adult and her request for civil assist as an adult) were redacted consistent with Florida law. Indeed, both reports wherein she made allegations of sexual misconduct were provided along with a checklist demonstrating that the law enforcement agency redacted the reports consistent with Florida law. The Florida law protects the identity of the alleged victim and the police reports produced by Defendant were all identity-redacted. See Menninger Decl., Ex. C and B (GM00755 and 00784). ‘A victim’s advocate shall not be examined as to any communication made to such victim’s advocate by a victim of domestic violence...or a victim of sexual assault, in person or through the media of written records or reports without the consent of the victim.” C.R.S. § 13-90-107(k)(1). 8

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Filename Giuffre_Maxwell_Batch4_p00367.png
File Size 316.7 KB
OCR Confidence 94.8%
Has Readable Text Yes
Text Length 2,198 characters
Indexed 2026-02-04 12:42:07.670862