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.447706.26.1
26 pg
…§ 1332.
complaint alleging that male celebrity had publicly
defamed her in statements made by individuals operating
at his direction or within scope of their employment. Cases that cite this headnote
Complaint was subsequently amended to include similar
claims by two…
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.447706.492.0
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.447706.29.0
2 pg
…among other things, that Cosby defamed an alleged sexual
assault victim by issuing statements to the press describing the allegations against him as
“unsubstantiated, fantastical stories…[that] have escalated far past the point of absurdity.” (Ex.
A at 8…
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.447706.1106.0_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.447706.1330.21
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.447706.1296.11
27 pg
…relevant to
the underlying action. Ransome objects to Defendant being permitted to utilize the underlying
action to obtain backdoor discovery into a separate action entirely unrelated to whether or not
Maxwell defamed Virginia Roberts Giuffre. Ransome further objects to this…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…relevant to
the underlying action. Ransome objects to Defendant being permitted to utilize the underlying
action to obtain backdoor discovery into a separate action entirely unrelated to whether or not
Maxwell defamed Virginia Roberts Giuffre. Ransome further objects to this…
giuffre-maxwell
gov.uscourts.nysd.447706.599.0
12 pg
…6.
Such
opinions are irrelevant and highly prejudicial and should be excluded.
In any event, are wholly irrelevant to the central
issue to be tried before the jury: whether Defendant defamed Ms. Gi…
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.447706.1330.15
43 pg
…brief, Ms. Giuffre alleges that defendant Ms. Ghislaine Maxwell
defamed her by calling her a "liar" for filing documents alleging that Maxwell and her boyfriend,
Jeffrey Epstein, had sexually abused her and trafficked her for sexual purposes. See Mccawley
Deel.…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…relevant to
the underlying action. Ransome objects to Defendant being permitted to utilize the underlying
action to obtain backdoor discovery into a separate action entirely unrelated to whether or not
Maxwell defamed Virginia Roberts Giuffre. Ransome further objects to this…
giuffre-maxwell
gov.uscourts.nysd.447706.513.0
21 pg
…Sanctions are, accordingly, obviously not appropriate.
I. INTRODUCTION
1
Of course, the facts at issue in this case began in January 2015, when Defendant
defamed Ms. Giuffre, leading to this lawsuit, filed in September 2015.
…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 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.447706.978.0
27 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.447706.977.0
27 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.447706.25.0
13 pg
…pleading burden here.
B. Ms. Maxwell’s Statements Are Protected by the Self-Defense Privilege
The long-recognized self-defense privilege “is available to one who has been defamed in
the first instance, and who, in response to the attack…
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