giuffre-maxwell
gov.uscourts.nysd.447706.1202.9
5 pg
…e*
101) assault*
102) juvenile*
103) seal*
104) joint* w/3 defen*
105) jda
106) roadhouse*
108) illegal*
109) immune*
110) prosecut*
111) law* w/3 enforc*
112) jane* w/3 *doe*
117) model*
118) actress*
123) vanity* w/ 3…
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…allegedly sexually assaulted 16-year-old Annie
Farmer
It reportedly happened at paedophile Epstein's 7,500-acre New Mexico
ranch
A lawyer for more than 20 of Epstein's victims has made the allegation
By Mark Hookham For The…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.18
5 pg
…e*
101) assault*
102) juvenile*
103) seal*
104) joint* w/3 defen*
105) jda
106) roadhouse*
107) grill*
108) illegal*
109) immune*
110) prosecut*
111) law* w/3 enforc*
112) jane* w/3 *doe*
117) model*
118) actress*
123) vanity…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.1_1
13 pg
…nor disseminate them to third parties. They contain personal, sensitive, and embarrassing
information. Many of them also concern minors and a victim of sexual assault; therefore, they are
protected by various state statutes. Ms. Giuffre requests that this Court maintain…
giuffre-maxwell
gov.uscourts.nysd.447706.1059.0
3 pg
…Doc.892, at 4-10. It found that “the
parties and multiple deponents have reasonably relied on the Protective Order in giving
testimony and producing documents including evidence of assault, medical records, and
emails,” and “[t]hird-party witnesses have…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…in filing a legal document on
their client's behalf which contained those allegations. As a result, the undisputed record
evidence establishes that Dershowitz waged a baseless international media assault on the
honesty, integrity, and professionalism of Edwards and Cassell…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.40
19 pg
…Joshua Bunner
Address unknown at this time
Joshua Bunner has knowledge concerning Plaintiff’s credibility, including false
claims of sexual assault.
13. Carolyn Casey
Address unknown at this time
Telephone number unknown at this time
3
Case 1:15-cv…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.18
50 pg
…i
Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 3 of 50
4. Sexual Assault Records are a Medical Event and Are Barred by This
Court’s Order ............................................................................................23
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.31
13 pg
…RFP No. 1 seeks documents Mr. Pagliuca allegedly ‘reviewed and/or relied upon’ in
allegedly making statements stating that Plaintiff previously made false accusations of sexual
assault.” (Br. at 5). (Emphasis original).
How Defendant purports to distinguish between the actual…
giuffre-maxwell
gov.uscourts.nysd.447706.515.0
12 pg
…lodge defamation claims against them. Indeed, just three weeks earlier, an accuser of Bill Cosby filed for defamation
based his then recent denials of a 2005 sexual assault. See CBS News, “Bill Cosby Hit with a Defamation Lawsuit,”
(Dec. 10…
giuffre-maxwell
gov.uscourts.nysd.447706.201.0
5 pg
…of, or witnesses to, sexual abuse and sexual crimes. Indeed, even
when they are plaintiffs, “sexual assault victims are a paradigmatic example of those entitled to a
grant of anonymity.” Doe No. 2 v. Kolko, 242 F.R.D. 193…
giuffre-maxwell
gov.uscourts.nysd.447706.23.0
32 pg
…Harass, And Intimidate........................................................17
II. Ms. Giuffre Has Properly Pled A Defamation Claim............................................18
A. Viewed In Context, Defendant’s Assault On Ms. Giuffre
Is Defamatory.. ...…
giuffre-maxwell
gov.uscourts.nysd.447706.881.0
8 pg
…A member of the Royal family? A foreigner?
SEXUAL ASSAULT
Has anyone been accused of being involved in sexual assault or sexual abuse of any type
or had a family member involved? (If so, we need to speak to…
giuffre-maxwell
1320-40
19 pg
…Joshua Bunner
Address unknown at this time
Joshua Bunner has knowledge concerning Plaintiff’s credibility, including false
claims of sexual assault.
13. Carolyn Casey
Address unknown at this time
Telephone number unknown at this time
3
Case 1:15-cv…
giuffre-maxwell
gov.uscourts.nysd.447706.29.0
2 pg
…among other things, that Cosby defamed an alleged sexual
assault victim by issuing statements to the press describing the allegations against him as
“unsubstantiated, fantastical stories…[that] have escalated far past the point of absurdity.” (Ex.
A at 8…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.11
13 pg
…RFP No. 1 seeks documents Mr. Pagliuca allegedly ‘reviewed and/or relied upon’ in
allegedly making statements stating that Plaintiff previously made false accusations of sexual
assault.” (Br. at 5). (Emphasis original).
How Defendant purports to distinguish between the actual…
giuffre-maxwell
gov.uscourts.nysd.447706.949.0
31 pg
…names and
16 substituting initials and things like that. They don't
17 identify the names of victims of sexual assaults.
18 But the law is such that we have to decide what
19 standard applies. But in any event…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…to, or with whom You
engaged in, any illegal or inappropriate sexual contact, conduct or assault prior to June 1999,
including the names of the individuals involved, the dates of any such illegal or inappropriate
sexual contact, conduct or assault…
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