gov.uscourts.nysd.447706.26.1.pdf PDF
…Courts Substance or procedure; determinativeness Federal courts sitting in diversity apply state Synopsis substantive law and federal procedur…
…Courts Substance or procedure; determinativeness Federal courts sitting in diversity apply state Synopsis substantive law and federal procedur…
…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…
…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 …
…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…
…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…
…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…
…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.. ...…
…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…
…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…
…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…
…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…
…Rather, on the way to the detox unit at the hospital, Plaintiff claimed she had been forcibly sexually assaulted by her friends. Plaintiff’s claim of forced sexual assault was expressly refuted by the witnesses, who also verified Plaintiff’s…
…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…
…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…
…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…
…the public interest privilege, and any other applicable privilege. Ms. Giuffre objects to the extent this seeks information regarding sexual assaults that occurred prior to her involvement with the Defendant and Jeffrey Epstein. Ms. Giuffre responds as follows: Ms. Giuffre…
…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…
…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…
…Cassell alleged that “[i]mmediately following the filing of what Dershowitz knew to be an entirely proper and well- founded pleading, Dershowitz initiated a massive public media assault on the reputation and character of Bradley J. Edwards and Paul G…
…the public interest privilege, and any other applicable privilege. Ms. Giuffre objects to the extent this seeks information regarding sexual assaults that occurred prior to her involvement with the Defendant and Jeffrey Epstein. Ms. Giuffre responds as follows: Ms. Giuffre…
Comments