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.447706.492.0
9 pg
…aware, Ms. Giuffre has alleged that Defendant defamed her when she
called her a liar after Ms. Giuffre spoke out about being a child victim of sex abuse at the hands of
Defendant and Defendant’s long-time boyfriend, convicted…
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.447706.562.2
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.447706.1328.4
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.447706.132.1
31 pg
…5 have not heard that term used, I think what she may be
6 referring to was the fact that this is a defamation claim and
7 the person who defamed my client was also an abuser, we allege.
8…
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.447706.1328.41
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.447706.1328.5
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.447706.1330.21
11 pg
…Cc:
Hi Ross, I'm working on a story about a defamation suit filed by Virginia Roberts against Ghislaine Maxwell.
Virginia alleges that Ghislaine defamed her by calling her claims "obvious lies," among other denials. Those denials were
released through…
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
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.447706.164.0
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…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 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.447706.977.1
25 pg
…2015, Giuffre filed the underlying action
against Maxwell in the Southern District of New York. Giuffre alleged
that Maxwell had defamed her through this and other public
statements. Extensive and hard‐fought discovery followed. Due to the
volume of sealing…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…publication, whether in print, internet, broadcast or some other
form of media.
7. State whether You believe that You have ever been defamed by anyone other than
Ghislaine Maxwell. If so, as to each alleged act of Defamation, state
a…
giuffre-maxwell
gov.uscourts.nysd.447706.63.0
22 pg
…Interrog. No. 6) and whether Plaintiff has been defamed by anyone other than
1
Plaintiff additionally asserts that no interrogatories are permitted pursuant to Local Rule 33.3
prior to the last 30 days of discovery. See Menninger Decl. Ex…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 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…