giuffre-maxwell
gov.uscourts.nysd.447706.1330.22
22 pg
…suicide. Even if AR is discredited by AD people will know JE paid her off and
believe G was complicate absent a credible denial.
Now it is reported that G engaged in direct abuse - as I feared would happen. Next…
giuffre-maxwell
gov.uscourts.nysd.447706.26.1
26 pg
…s statement that alleged victim’s accusation
that he had sexually assaulted her was “10-year-old, Cases that cite this headnote
discredited accusation that proved to be nothing at the
time, and is still nothing” was not substantially true…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…on a helicopter to Mr. Epstein’s Island – a story which has since been fully discredited as a lie.
This is simply one example of names and stories that were mysteriously added to Plaintiff’s
story, likely through Churcher’s…
giuffre-maxwell
gov.uscourts.nysd.447706.562.1
13 pg
…among other
things, calling Giuffre a liar in published statements with the malicious intent of discrediting and
further damaging Giuffre worldwide.
JURISDICTION AND VENUE
2. This is an action for damages in an amount in excess of the minimum
jurisdictional…
giuffre-maxwell
gov.uscourts.nysd.447706.1.0
12 pg
…among other
things, calling Giuffre a liar in published statements with the malicious intent of discrediting and
further damaging Giuffre worldwide.
JURISDICTION AND VENUE
2. This is an action for damages in an amount in excess of the minimum
jurisdictional…
giuffre-maxwell
gov.uscourts.nysd.447706.24.1
13 pg
…among other
things, calling Giuffre a liar in published statements with the malicious intent of discrediting and
further damaging Giuffre worldwide.
JURISDICTION AND VENUE
2. This is an action for damages in an amount in excess of the minimum
jurisdictional…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.38
8 pg
…again, willfully disclosed confidential, alleged settlement negotiations
in a brazen and self-serving attempt to discredit one of his accusers during the continuation of his
deposition in this case:
Q. And the lawyers generically, he's talking about the lawyers…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.3
223 pg
…BORJA: I'm entitled to know the names
24 of witnesses who can either verify or discredit
25 the allegations.
CONFIDENTIAL
Case 1:15-cv-07433-LAP Document 1335-3 Filed 01/09/24 Page 32 of 223
…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.3
21 pg
…articles
publishing plaintiff’s allegations and drawing on his experience and training as a lawyer, Mr.
Barden crafted a response with the goal of discrediting plaintiff and what the statement called
plaintiff’s new” allegations. Summary Judgment Motion at 27…
giuffre-maxwell
gov.uscourts.nysd.447706.179.0
22 pg
…ordered an in camera inspection of
documents sent to and from an attorney of record and his client regarding the case at issue.
Defendant’s attempt to draw a parallel to her public relations campaign to defame and discredit
Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.406.0
31 pg
…media rather than try it before the court, Dershowitz filed a false affidavit
with the Florida court purporting to describe confidential settlement communications with
Giuffre’s counsel and attempting to discredit Giuffre. He filed his affidavit in the public court…
giuffre-maxwell
gov.uscourts.nysd.447706.63.0
22 pg
…including documents that
are key to this case. Plaintiff contends that Ms. Maxwell began her “campaign to discredit” her
following her December 30, 2014 pleading in the U.S. District Court in which she attempted to
join the Crime Victims…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.12
223 pg
…Counsel?
23 MS. BORJA: I'm entitled to know the names
24 of witnesses who can either verify or discredit
25 the allegations.
CONFIDENTIAL
31
1 MS. MCCAWLEY: She's given you the name.
2 SPECIAL MASTER: Counsel, let…
giuffre-maxwell
gov.uscourts.nysd.447706.23.0
32 pg
…at ¶ 23-25.
“In January 2015, Maxwell undertook a concerted and malicious campaign to discredit
Giuffre and damage her reputation that Giuffre’s factual reporting of what happened to her
would not be credited.” Id. at ¶ 28.
“As…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.22
31 pg
…media rather than try it before the court, Dershowitz filed a false affidavit
with the Florida court purporting to describe confidential settlement communications with
Giuffre’s counsel and attempting to discredit Giuffre. He filed his affidavit in the public court…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.3_2
12 pg
…widen-probe-include-Ghislaine-Maxwell.html
103 https://www.dailymail.co.uk/news/article-8872327/Jeffrey-Epstein-told-Ghislaine-Maxwell-reward-discredit-Virginia-Roberts.html
104 https://globalnews.ca/news/7412928/ghislaine-maxwell-transcript-jeffrey-epstein/
105 https://in.reuters…
giuffre-maxwell
gov.uscourts.nysd.447706.15.0
29 pg
…true?” Ms. Maxwell then responds
“C’mon guys” and walks away. According to the Complaint, this “response” demonstrates Ms.
Maxwell’s “continued…campaign to falsely and maliciously discredit” Plaintiff. Compl. ¶ 37.
The Complaint does not allege damages in detail…