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.447706.1078.5
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.447706.1320.40
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.447706.23.0
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
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.447706.1219.11
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.447706.1256.8
16 pg
…Evid. 415(a)( (“In a civil case involving a claim for relief based on a
party’s alleged sexual assault or child molestation, the court may admit evidence that the party
committed any other sexual assault or child molestation.”).
Entirely…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…Exhibit. 5, Complaint in Edwards and Cassell
v. Dershowitz. The complaint alleged that Dershowitz had engaged in a “massive public media
assault on the reputation and character” of Cassell and Edwards. Id. at 4. Ms. Giuffre was not a
party…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.11
15 pg
…Evid. 415(a)( (“In a civil case involving a claim for relief based on a
party’s alleged sexual assault or child molestation, the court may admit evidence that the party
committed any other sexual assault or child molestation.”).
Entirely…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 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…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…the plaintiff in this lawsuit, and
republished all over the world. Professor Dershowitz has done everything in his power to
combat this assault on his reputation, from proclaiming his innocence in public, to marshalling
every bit of information within his…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.22
22 pg
…THIS CASE, WHICH IS NOT
UNU TIME WA •OTIONAL AND CRIED DURING THE INTERVIEW .
SAID THAT SHE,, MET THE SUSPECTS FROM THIS INCIDENT
AT A PARTY SEVERAL WEEKS PRIOR TO/ THE ASSAULTS, WHICH OCCURRED SOMETIME
AROUND THE 1ST OF FEBRUARY. …
giuffre-maxwell
gov.uscourts.nysd.447706.1343.1
23 pg
…were minors who gave reports
9 to police just like the one we just read that
10 they were sexually assaulted by Jeffrey
11 Epstein in the Palm Beach home during the
12 years that you were working with him…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…inter alia, Plaintiff was widely reputed prior to any such
communication to be a liar, a person who falsifies claims of sexual assault, and a sexually
permissive woman, because Plaintiff already had substantial mental and medical conditions that
pre-existed…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…COURT: Yes.
9 MS. McCAWLEY: Sorry. So with respect to the reason
10 why individuals who may have been victims of sexual assault
11 would be confidential, there is case law that we cite in our
12 brief, Doby v…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.24
16 pg
…offers no explanation for her convenient
forgetfulness. Moreover, evidence of being recruited by Defendant and being sexually assaulted
is not something Ms. Giuffre can obtain through requests for production or through
interrogatories. The only way of obtaining such evidence is…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.17_1
16 pg
…offers no explanation for her convenient
forgetfulness. Moreover, evidence of being recrnited by Defendant and being sexually assaulted
is not something Ms. Giuffre can obtain through requests for production or through
intenogatories. The only way of obtaining such evidence is…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.27
15 pg
…offers no explanation for her convenient
forgetfulness. Moreover, evidence of being recruited by Defendant and being sexually assaulted
is not something Ms. Giuffre can obtain through requests for production or through
interrogatories. The only way of obtaining such evidence is…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…confidential).
Part of Defendant’s frantic attempt to discredit Ms. Giuffre is to publicly reveal that she
was sexually assaulted as a 14 year old, yet announce to the world that she “cried rape,”13 and to
humiliate her family…