giuffre-maxwell
gov.uscourts.nysd.447706.541.0
10 pg
…33
IV. Ms. Maxwell’s January 4, 2015, statement is nonactionable. ............................................... 38
V. The defamation claim should be dismissed because the publication is substantially true. ... 39
VI. Plaintiff cannot establish actual malice by clear and convincing evidence. .......................... 40
A.…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.14
3 pg
… Philip Barden
Subject: VR cried rape - prior case dismissed as prosecutors found her 'not credible'
Ghislaine
Some helpful leakage...
In today's Daily Mail print edition and on web
vvww.dailymail.co.uk/news/article-2965360/Prince-Andrew-s-sex…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.2
3 pg
… Philip Barden
Subject: VR cried rape - prior case dismissed as prosecutors found her 'not credible'
Ghislaine
Some helpful leakage ...
In today's Daily Mail print edition and on web
www.dailymail .eo.uk/news/article-2965360/Prince-Andrew-s-sex…
giuffre-maxwell
1320-14
3 pg
… Philip Barden
Subject: VR cried rape - prior case dismissed as prosecutors found her 'not credible'
Ghislaine
Some helpful leakage...
In today's Daily Mail print edition and on web
vvww.dailymail.co.uk/news/article-2965360/Prince-Andrew-s-sex…
giuffre-maxwell
gov.uscourts.nysd.447706.2.0
2 pg
…SONY at any time? Nfiles0iudge Previously Assigned
If yes, wa s this case Vol. D In vol. D Dismissed . No D Yes D If yes, give d a t e - - - - - -- - -- & Ca se No . .
Is THIS AN INTERNATIONAL ARBlT RATION CASE! …
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…
f. the disposition of any case associated with any such Communication,
irrespective of whether the matter was sealed, expunged or later dismissed.
Response to Interrogatory No. 4
Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…
f. the disposition of any case associated with any such Communication,
irrespective of whether the matter was sealed, expunged or later dismissed.
Response to Interrogatory No. 4
Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…
f. the disposition of any case associated with any such Communication,
irrespective of whether the matter was sealed, expunged or later dismissed.
Response to Interrogatory No. 4
Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…
f. the disposition of any case associated with any such Communication,
irrespective of whether the matter was sealed, expunged or later dismissed.
Response to Interrogatory No. 4
Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…Communication;
f. the disposition of any case associated with any such Communication, irrespective
of whether the matter was sealed, expunged or later dismissed.
5. Identify each Communication that You or Your Attorneys have had with any
author, reporter, correspondent, columnist…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…
f. the disposition of any case associated with any such Communication,
irrespective of whether the matter was sealed, expunged or later dismissed.
Response to Interrogatory No. 4
Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33…
giuffre-maxwell
1320-37
48 pg
…
f. the disposition of any case associated with any such Communication,
irrespective of whether the matter was sealed, expunged or later dismissed.
Response to Interrogatory No. 4
Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33…
giuffre-maxwell
gov.uscourts.nysd.447706.71.3
40 pg
…
f. the disposition of any case associated with any such Communication,
irrespective of whether the matter was sealed, expunged or later dismissed.
Response to Interrogatory No. 4
Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…
f. the disposition of any case associated with any such Communication,
irrespective of whether the matter was sealed, expunged or later dismissed.
Response to Interrogatory No. 4
Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33…
giuffre-maxwell
gov.uscourts.nysd.447706.1318.0
3 pg
…ask the Court to
extend the time, as established in its endorsement of October 27, 2023
(discussed below), for my client and I to submit supplemental materials in
support of continued sealing, should the Court still be considering whether to
…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.1
2 pg
…ARGUMENT REQUESTED
:
:
------------------------------------------------------- x
DEFENDANT GHISLAINE MAXWELL’S NOTICE OF MOTION UNDER THE DUE
PROCESS CLAUSE TO SUPPRESS ALL EVIDENCE OBTAINED FROM THE
GOVERNMENT’S SUBPOENA TO …
giuffre-maxwell
gov.uscourts.nysd.447706.1325.4
6 pg
…delaying me.
We were serving subpoenas on dates that we thought are grouped within the locations/date ranges we discussed during
the meet and confer and since we have been having an extraordinarily difficult time serving witnesses who appear to…
giuffre-maxwell
gov.uscourts.nysd.447706.1317.0
3 pg
…ask the Court to
extend the time, as established in its endorsement of October 27, 2023
(discussed below), for my client and I to submit supplemental materials in
support of continued sealing, should the Court still be considering whether to
…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.14
4 pg
…other words hundreds of thousands of non-responsive documents. Your search terms include “bill”
and thus are likely to include every bill that our client has received or sent or discussed. Your search terms include Philip
Barden who the court…
giuffre-maxwell
gov.uscourts.nysd.447706.135.0
37 pg
…6', , 2,016 ~ Opinion denying
:'"' .' .~ . .
Defendant's motion to dismiss, this case concerns Defendant's
statements denying Plaintiff's allegations concerning
Defendant's role in Plaintiff's sexual abuse as a mi…