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.447706.1201.10_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.447706.1199.16_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.447706.1328.21
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.447706.1327.26
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.447706.1325.18
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.447706.1137.18_2
15 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.447706.1137.16_2
15 pg
…offers no explanation for her convenient
forgetfulness. Moreover, evidence of being recmited 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.447706.1320.21
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.447706.881.0
8 pg
…A member of the Royal family? A foreigner?
SEXUAL ASSAULT
Has anyone been accused of being involved in sexual assault or sexual abuse of any type
or had a family member involved? (If so, we need to speak to…
giuffre-maxwell
1320-21
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
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
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.447706.29.1
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.447706.1327.18
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.447706.1199.1_1
13 pg
…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…