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.447706.26.1
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.447706.1325.19
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.447706.31.0_1_1
22 pg
…4 law of defamation stands by their side. It does not allow
5 someone to publically proclaim they're a liar and issue
6 character assaults on them without ramifications.
7 After those statements were made, we filed this
8 …
giuffre-maxwell
gov.uscourts.nysd.447706.589.0
24 pg
…of the record, and nothing in the instant motion should lead to a different conclusion.
Additionally, Cernovich’s previous statements regarding sexual assault belie his
professed purpose of promoting “openness in the judicial branch,” (Mot. at 3), and instead point…
giuffre-maxwell
gov.uscourts.nysd.447706.851.0
158 pg
…this is Meredith Schultz for
22 the plaintiff. The next article in the omnibus motion is to
23 exclude testimony references to prior sexual assault. This is
24 an issue that I spoke on yesterday related to another motion
25…
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.447706.949.0
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.447706.201.0
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.447706.29.0
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.447706.1320.28
32 pg
…others that he has never reported to any law enforcement even though he claims that
he witnessed potential kidnappings and sexual assaults on children.5 Plaintiff’s claim that Mr.
Rizzo is an “example of delay that has harmed [her…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…the discovery sought from the Maxwell case is believed
to be particularly relevant to Dershowitz’s defense of the sexual assault claims which Giuffre has
brought against him on the theory that he was “on notice” that she was being…
giuffre-maxwell
gov.uscourts.nysd.447706.1240.0
5 pg
…demonstrated at length at Ms. Maxwell’s recent criminal
trial, this case concerns the widespread abuse, sexual assault and trafficking of minors. It was only
after and because of Intervenors' investigative reporting that Mr. Epstein and Ms. Maxwell were
arrested…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.17
13 pg
…motion. Doc.892. Among
other things, the Court 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.” Id. at 6. Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…others that he has never reported to any law enforcement even though he claims that
he witnessed potential kidnappings and sexual assaults on children.5 Plaintiff’s claim that Mr.
Rizzo is an “example of delay that has harmed [her…
giuffre-maxwell
gov.uscourts.nysd.447706.89.0
10 pg
…Protective Order’s restrictions. Professor Cassell and Mr.
Edwards have worked with confidentiality orders in many other cases, including cases involving
sexual assault victims, and they are confident that compliance here will not be a problem.
Therefore, the Court should…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…Supp. 3d at 445 (summarily concluding that all
“[t]he Summary Judgment Judicial Documents openly refer to and discuss these
allegations [of sexual assault and sexual trafficking] in comprehensive detail, and
that those allegations “establish[] a strong privacy interest here…
giuffre-maxwell
gov.uscourts.nysd.447706.1113.0
7 pg
…against the unilateral disclosure that Mr. Dershowitz seeks. Those
interests are particularly acute given that the psychological and
emotional wellbeing of survivors of alleged sexual assaults may be
implicated by such a broad disclosure. Indeed, protecting such
interests is one…
giuffre-maxwell
1320-28
32 pg
…others that he has never reported to any law enforcement even though he claims that
he witnessed potential kidnappings and sexual assaults on children.5 Plaintiff’s claim that Mr.
Rizzo is an “example of delay that has harmed [her…