giuffre-maxwell
gov.uscourts.nysd.447706.26.1
26 pg
…in order for
of allegedly defamatory statement gave rise to defamation claim to survive motion to dismiss,
new defamation claim against purported allegedly defamatory statement must contain at
defamer, and thus statute of limitations did not least one false factual…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.6
10 pg
…of
the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution ofthe
United States to a speedy trial or to bar the prosecution by reason of the running of the statute
of limitations for a period of…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…or
alluded to in Your Complaint, or any that could be included in any amended complaint in this
action.
7. “Employment” includes without limitation, the provision of work and/or services,
whether paid or unpaid, whether as an employee, intern…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…7
Statutes
Fed. R. Civ. P. 26 ......................................................................................................................3, 22
Fed. R. Civ. P. 37 ........................................................................................................................4, 8
Fed. R. Evid. 501 ...............…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.1
18 pg
…1983) (failure to produce
documents and supply adequate answers to interrogatories without justifiable excuse warranted
the dismissal of the complaint). The blatant nature of the defendant’s failure to participate in
discovery is akin to the conduct for which the…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.4
40 pg
…and her attorneys’ communications with media representatives concerning the
subject matter of this action. Plaintiff and her attorney’s communications with the media are
directly relevant to numerous defenses available to Ms. Maxwell, including without limitation,
her self-defense privilege…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.15
11 pg
…to Dismiss in the matter
before Judge Koeltl. The Epstein Defendants argue that the materials can be used to establish
that Jane Doe 43’s claims should be barred because they are outside the ten (10) year statute of
limitation…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…2002) (Ellis, M.J.). See Motion to Compel at 8. As discussed
below, as a matter of controlling federal authority, these cases have been repudiated by the
Second Circuit. And to the same effect, Florida law also rejects the expansive…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…and information, including without limitation,
documents produced, answers to interrogator ies, responses to
requests for admission, deposition testimony, and other
information disclosed pursuant to the disclosure or discovery
duties created by the Federal Rules of Civil Procedure." Id. 'IT
1…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.14_2
40 pg
…2002) (Ellis, M.J.). See Motion to Compel at 8. As discussed
below, as a matter of controlling federal authority, these cases have been repudiated by the
Second Circuit. And to the same effect, Florida law also rejects the expansive…
giuffre-maxwell
1320-18
40 pg
…2002) (Ellis, M.J.). See Motion to Compel at 8. As discussed
below, as a matter of controlling federal authority, these cases have been repudiated by the
Second Circuit. And to the same effect, Florida law also rejects the expansive…
giuffre-maxwell
gov.uscourts.nysd.447706.218.0
25 pg
…using multiple different email accounts. See Churcher Decl. ¶ 10.7
Moreover, as discussed above, much of Ms. Churcher’s communications with and about
Ms. Roberts involved information that Ms. Churcher received in confidence. Even if those
communications were not protected…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.18
50 pg
…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
5. Information About Ms. Giuff…
giuffre-maxwell
gov.uscourts.nysd.447706.54.0
11 pg
…DEFENSES
23. The Complaint fails to state a claim upon which relief could be granted.
24. Plaintiff’s claims may be barred by the statute of limitations.
25. Plaintiff’s claims are barred by the “single publication” rule.
26. Plaintiff…
giuffre-maxwell
gov.uscourts.nysd.447706.931.0
15 pg
… One set of
10 them are a bunch of photographs. I have looked at them,
11 nothing prurient about them, they all predate the statute of
12 limitations time period and were used during the deposition.
13 THE COURT: Yes…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…him again.”
Instead, Boies said that Dershowitz has reverted to a “very sad” PR campaign against the lawyers
representing Roberts.
Dershowitz disputed Boies’s comments that he declined to waive the statute of limitations, saying that he
filed an affidavit…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.12
10 pg
…were part of
the sexual trafficking ring that Defendant was a party to and she has known about them and
interacted with them for years. Ms. Ransome's claim had to be filed swiftly because her statute
of limitations was…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.6
134 pg
…22 question, we can use the invocation that we 22 taken on the absence of the meaningful
23 just did in response to your second 23 Statute of Limitations, in terms of our
24 question, or we simply can say…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…precepts of fairness.
More practically, nothing precludes participants in this matter from publicly disclosing
their own allegations with more particularity. This is true in two key respects. First, New
York’s recent legislation extending and revising the statute of limitations…
giuffre-maxwell
gov.uscourts.nysd.447706.1338.1
134 pg
…22 question, we can use the invocation that we 22 taken on the absence of the meaningful
23 just did in response to your second 23 Statute of Limitations, in terms of our
24 question, or we simply can say…
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