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.447706.26.0
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.447706.1328.20
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.447706.1201.10_1
27 pg
…5-15.
She discussed her knowledge of . Id. at 55:17- 56:20.
She had no knowledge of telling the police that Jeffrey Epstein sexually
assaulted her. Id. at 56:16-20.
She had no knowledge of …
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
… Whether Defendant was aware that there were over 30 individuals who were minors who
gave reports to the Palm Beach Police Department who said they were sexually assaulted
by Epstein during the years that Defendant was working with him…
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.447706.1199.16_1
12 pg
…s sex trafficking while attempting to strike down
Ms. Giuffre designations about such things as being sexually assaulted while a child.
Given the extremity of the position she is staking out, it is unsurprising that Defendant’s
entire brief cites…
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.447706.1320.10
28 pg
…81.
! Whether Defendant was aware that there were over 30 individuals who were minors who
gave reports to the Palm Beach Police Department who said they were sexually assaulted
by Epstein during the years that Defendant was working with him…
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.447706.1320.24
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.26
27 pg
…15.
x She discussed her knowledge of Annie Farmer. Id. at 55:17- 56:20.
x She had no knowledge of Annie Farmer telling the police that Jeffrey Epstein sexually
assaulted her. Id. at 56:16-20.
x She had…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.11_3
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.447706.1218.50
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 …