giuffre-maxwell
gov.uscourts.nysd.447706.24.3
3 pg
…says claims against her are ‘lies’
The daughter of disgraced Mirror newspapers chief Robert Maxwell said her character had been defamed.
Case 1:15-cv-07433-RWS Document 24-3 Filed 12/17/15 Page 3 of 3
Documents…
giuffre-maxwell
gov.uscourts.nysd.447706.29.1
18 pg
…JR., an
individual also known as BILL COSBY,
Defendant.
MEMORANDUM OPINION
The very detailed and complete Complaint in this case alleges that by making or causing
to be made three very discreet statements: (1) Defendant defamed Plaintiff, (2) Defendant cast…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…The two lawyers alleged that Dershowitz defamed them when he claimed
that they knowingly filed a lawsuit containing falsehoods about him or at least failed to
properly investigate their client’s allegations that Dershowitz had sexual relations with her
when…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.42
9 pg
…Paul, Alan Dershowitz, hours ago, has
filed this countersuit in Florida because he feels he's being defamed by this lawsuit
by this woman, Virginia Roberts. CNN is naming her because she has gone public
with her name. So is…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…Alan Dershowitz, defamed them by
repeatedly claiming in worldwide media broadcasts and other widely-disseminated statements
that they had engaged in conspiring with their client to make up sexual abuse allegations against
Dershowitz. The pleadings and discovery taken to date…
giuffre-maxwell
gov.uscourts.nysd.447706.363.8
3 pg
…allegations of their client, not whether the acts
of alleged misconduct in fact occurred. Edwards and Cassell vigorously denied the
contention that they had acted improperly and asserted that it defamed them. Dershowitz
countersued Edwards and Cassell, alleging they had…
giuffre-maxwell
gov.uscourts.nysd.447706.102.0
9 pg
…As the Court is well aware from previously filed pleadings, this is a single-count
defamation case, turning on whether Defendant defamed Ms. Giuffre by calling her a liar when
Ms. Giuffre reported the sexual abuse she suffered as a…
giuffre-maxwell
gov.uscourts.nysd.447706.354.0
40 pg
…the
conferral, Plaintiff’s counsel wrote a letter declining to supplement any of the responses to the
Second Set of Discovery Requests.
PRELIMINARY STATEMENT
Plaintiff has brought a lawsuit alleging Ms. Maxwell defamed her. The defamation
consisted of Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…the complaint). The blatant nature of the defendant’s failure to participate in
discovery is akin to the conduct for which the Second Circuit has awarded sanctions.
This case turns on whether or not Maxwell defamed Ms. Giuffre when she…
giuffre-maxwell
gov.uscourts.nysd.447706.363.6
15 pg
…Jane Doe No. 3. None of that childhood abuse is relevant to this case
which involves the narrow issue of whether Defendant defamed two lawyers. Defendant’s
subpoena is both unreasonable and oppressive and should be quashed. See Matthews v…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…information requested above is
in the possession of Defendant who has failed to comply with her production obligations in
this matter.
7. State whether You believe that You have ever been defamed by anyone other than
Ghislaine Maxwell. If so…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…collateral” attack on Plaintiff’s credibility,
but much more importantly, to disprove Giuffre’s claims that Dershowitz defamed her by calling
her a “serial liar” and stating that she has a “documented history of lying about prominent people.”
Am. Compl.…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…engaged in sexual relations with Mr. Dershowitz,
something he adamantly and publicly denied.
At the heart of this case is the question of whether Ms. Maxwell defamed Plaintiff by
calling her a liar. Of course, if Plaintiff is a liar…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…Ms.
Giuffre, Dershowitz called those girls liars and defamed them as prostitutes,14 in an effort to
convince the State Attorney that these girls could not even believably establish that they had ever
even gone to Epstein’s mansion. Later…
giuffre-maxwell
gov.uscourts.nysd.447706.1069.0
25 pg
…Professor Dershowitz has to defend
10 himself, and he will defend himself, by proving the truth of
11 what it is that he is alleged to have defamed Ms. Giuffre
12 about. And if one were to look at paragraphs…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.2
23 pg
…Maxwell, a civil defamation case Virginia
Giuffre filed in 2015. Giuffre claimed that Maxwell defamed her when Maxwell’s attorney-hired
press agent denied as “untrue” and “obvious lies” Giuffre’s numerous allegations, over the span
of four years, that…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…5 Filed 01/05/24 Page 10 of 45
This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
7. State whether You believe that You have ever been defamed by anyone other than
Ghislaine Maxwell. If so…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…information requested above is in the possession of Defendant who has failed to comply with
her production obligations in this matter.
7. State whether You believe that You have ever been defamed by anyone other than
Ghislaine Maxwell. If so…
giuffre-maxwell
gov.uscourts.nysd.447706.1071.0
13 pg
…was underage. Ms. Giuffre
alleges that Mr. Dershowitz’s false denial of such contact defamed
her. To be sure, the two actions are related because they involve
the alleged behavior of individuals who were in Epstein’s
substantial orbit, but…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.4_1
29 pg
…Dershowitz”) for defamation in Florida state court. The subject matter of that
litigation concerned whether Mr. Dershowitz defamed Plaintiff’s attorneys by claiming
a) Plaintiff is lying; b) Edwards and Cassell knew Plaintiff is lying; c) Edwards and Cassell helped…