giuffre-maxwell
gov.uscourts.nysd.447706.1330.23
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.447706.24.3
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.447706.1256.8
16 pg
…job was for Epstein.8
That other young females were similarly recruited by the Defendant is evidence that Ms.
Giuffre is telling the truth about her experiences – and thus direct evidence that Defendant
defamed her when calling her a liar…
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.447706.1219.22
22 pg
…of a Court order requiring production of the
materials.
1
Case 1:15-cv-07433-LAP Document 1219-22 Filed 07/15/21 Page 2 of 22
financial information from just the time during which Defendant has defamed Ms…
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.447706.363.8
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.447706.354.0
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.447706.132.1
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.447706.363.6
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.447706.1325.1
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.447706.1069.0
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.447706.1256.11
15 pg
…job was for Epstein.7
That other young females were similarly recruited by the Defendant is evidence that Ms.
Giuffre is telling the truth about her experiences – and thus direct evidence that Defendant
defamed her when calling her a liar…
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.447706.1071.0
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.447706.1330.21
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…
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