giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…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…
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.447706.1328.21
19 pg
…rescue wagon with tbe victim
while she was being transported to the hospital. She states that the
victim had indicated to her that she had been assaulted, and she had
also seen what appears to be blood on the victims…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.50
15 pg
…produced, not the Requested
Documents. Pl. Br. at 22 (discussing “testimony about being sexually assaulted,” “personal
medical records,” and “personal emails with close family members”). But reasonable reliance is
determined on a document-by-document basis. See, e.g., Lown…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.18
23 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.447706.29.1
18 pg
…who just came forward for the first time ever asserted a legal
claim back at the time they allege they had been sexually assaulted.” The remainder of the
Martin Singer Statement chastises “the media” for failing to corroborate the new
…
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.447706.1199.6_1
14 pg
…Ex. H (GM00810-00840). Plaintiff alleges she was assaulted by her husband as witnessed
by at least one of their children. Plaintiff’s husband was charged with domestic violence, pled
guilty and was placed on probation.
Designation as Confidential
After…
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.447706.1327.18
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.447706.1059.0
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.447706.562.2
29 pg
…in filing a legal document on
their client's behalf which contained those allegations. As a result, the undisputed record
evidence establishes that Dershowitz waged a baseless international media assault on the
honesty, integrity, and professionalism of Edwards and Cassell…
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.447706.1328.18
50 pg
…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
…
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.447706.1330.2
40 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.447706.1320.28
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.447706.1320.18
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…