giuffre-maxwell
gov.uscourts.nysd.447706.1330.23
9 pg
…aware, Ms. Giuffre has alleged that Defendant defamed her when she
called her a liar after Ms. Giuffre spoke out about being a child victim of sex abuse at the hands of
Defendant and Defendant’s long-time boyfriend, convicted…
giuffre-maxwell
gov.uscourts.nysd.447706.24.3
3 pg
…says claims against her are ‘lies’
The daughter of disgraced Mirror newspapers chief Robert Maxwell said her character had been defamed.
Case 1:15-cv-07433-RWS Document 24-3 Filed 12/17/15 Page 3 of 3
Documents…
giuffre-maxwell
gov.uscourts.nysd.447706.26.1
26 pg
…§ 1332.
complaint alleging that male celebrity had publicly
defamed her in statements made by individuals operating
at his direction or within scope of their employment. Cases that cite this headnote
Complaint was subsequently amended to include similar
claims by two…
giuffre-maxwell
gov.uscourts.nysd.447706.29.1
18 pg
…JR., an
individual also known as BILL COSBY,
Defendant.
MEMORANDUM OPINION
The very detailed and complete Complaint in this case alleges that by making or causing
to be made three very discreet statements: (1) Defendant defamed Plaintiff, (2) Defendant cast…
giuffre-maxwell
gov.uscourts.nysd.447706.492.0
9 pg
…aware, Ms. Giuffre has alleged that Defendant defamed her when she
called her a liar after Ms. Giuffre spoke out about being a child victim of sex abuse at the hands of
Defendant and Defendant’s long-time boyfriend, convicted…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.8
16 pg
…job was for Epstein.8
That other young females were similarly recruited by the Defendant is evidence that Ms.
Giuffre is telling the truth about her experiences – and thus direct evidence that Defendant
defamed her when calling her a liar…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…The two lawyers alleged that Dershowitz defamed them when he claimed
that they knowingly filed a lawsuit containing falsehoods about him or at least failed to
properly investigate their client’s allegations that Dershowitz had sexual relations with her
when…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.42
9 pg
…Paul, Alan Dershowitz, hours ago, has
filed this countersuit in Florida because he feels he's being defamed by this lawsuit
by this woman, Virginia Roberts. CNN is naming her because she has gone public
with her name. So is…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…Alan Dershowitz, defamed them by
repeatedly claiming in worldwide media broadcasts and other widely-disseminated statements
that they had engaged in conspiring with their client to make up sexual abuse allegations against
Dershowitz. The pleadings and discovery taken to date…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…of a Court order requiring production of the
materials.
1
Case 1:15-cv-07433-LAP Document 1219-22 Filed 07/15/21 Page 2 of 22
financial information from just the time during which Defendant has defamed Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…of a Court order requiring production of the
materials.
1
Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05/24 Page 2 of 22
financial information from just the time during which Defendant has defamed Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.4
40 pg
…the
conferral, Plaintiff’s counsel wrote a letter declining to supplement any of the responses to the
Second Set of Discovery Requests.
PRELIMINARY STATEMENT
Plaintiff has brought a lawsuit alleging Ms. Maxwell defamed her. The defamation
consisted of Ms. Maxwell…
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.447706.363.8
3 pg
…allegations of their client, not whether the acts
of alleged misconduct in fact occurred. Edwards and Cassell vigorously denied the
contention that they had acted improperly and asserted that it defamed them. Dershowitz
countersued Edwards and Cassell, alleging they had…
giuffre-maxwell
gov.uscourts.nysd.447706.102.0
9 pg
…As the Court is well aware from previously filed pleadings, this is a single-count
defamation case, turning on whether Defendant defamed Ms. Giuffre by calling her a liar when
Ms. Giuffre reported the sexual abuse she suffered as a…
giuffre-maxwell
gov.uscourts.nysd.447706.354.0
40 pg
…the
conferral, Plaintiff’s counsel wrote a letter declining to supplement any of the responses to the
Second Set of Discovery Requests.
PRELIMINARY STATEMENT
Plaintiff has brought a lawsuit alleging Ms. Maxwell defamed her. The defamation
consisted of Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…the complaint). The blatant nature of the defendant’s failure to participate in
discovery is akin to the conduct for which the Second Circuit has awarded sanctions.
This case turns on whether or not Maxwell defamed Ms. Giuffre when she…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
…5 have not heard that term used, I think what she may be
6 referring to was the fact that this is a defamation claim and
7 the person who defamed my client was also an abuser, we allege.
8…
giuffre-maxwell
gov.uscourts.nysd.447706.363.6
15 pg
…Jane Doe No. 3. None of that childhood abuse is relevant to this case
which involves the narrow issue of whether Defendant defamed two lawyers. Defendant’s
subpoena is both unreasonable and oppressive and should be quashed. See Matthews v…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…information requested above is
in the possession of Defendant who has failed to comply with her production obligations in
this matter.
7. State whether You believe that You have ever been defamed by anyone other than
Ghislaine Maxwell. If so…
Comments