…Sun, Jan 4, 2015 Ghislaine Maxwell: ‘I was not a madam for paedophile’ SOCIALITE Ghislaine Maxwell dismissed claims yesterday that she acted as a “madam” to supply underage girls to US businessman Jeffrey Epstein. PUBLISHED: 00:10, Sun, Jan 4…
…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.…
…parties entered into a settlement agreement resolving all matters relating to the lawsuit. On May 25, 2017, “[t]his action was settled and dismissed with prejudice pursuant to a joint stipulation for dismissal.” Sealed Op., at 3 (Nov. 14, 2017)…
…Esq. motion to appear pro hac vice in this matter. This letter provides: (1) the stipulation for dismissal of the litigation referenced in the Defendant’s objection to the pro hac vice motion; (2) an affidavit from Bradley J. Edwards…
…statements, that will do it. … MR. EDWARDS: Sure. … There are two ways in which a case can be dismissed in Florida. One is by way of a court order. The other is by way of a stipulation. That…
…parties entered into a settlement agreement resolving all matters relating to the lawsuit. On May 25, 2017, “[t]his action was settled and dismissed with prejudice pursuant to a joint stipulation for dismissal.” Sealed Op., at 3 (Nov. 14, 2017)…
…this has been Defendant’s strategy, and the Court should not accept such stonewalling as a litigation tactic. In the Second Circuit, courts have dismissed actions where a party has demonstrated willful disregard for its discovery obligations. Edwards v. Am…
…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.…
…2015 WL 4610422 (S.D.N.Y. July 23, 2015) (granting in part motion to compel production). In the Second Circuit, courts have dismissed actions where a party has demonstrated willful disregard for its discovery obligations. Edwards v. Am. Airlines…
…there 4 is a statement, some kind of a statement from the mediator in 5 the Florida action. When I get a piece of paper that says the 6 Florida action is dismissed, a court order or whatever, then 7 …
… 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…
…2016. (Doc. #13) On November 30, 2015, contemporaneous with the filing of her Rule 12(b) Motion to Dismiss, Ms. Maxwell also requested of this Court a stay of discovery pursuant to Rule 26(c). (Doc. #17) That motion was…
…I may well do so.” Asked if Boies has considered bringing his own defamation lawsuit against Dershowitz, Boies dismissed the possibility, saying “almost all public debate belongs in the public field… I’m also comfortable with the public record…
… 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…
…4 on behalf of the defendant Maxwell. We are the movant for the 5 purposes of today's hearing. I filed both a motion to dismiss 6 the complaint, which is based on one claim of defamation, as 7 well…
… 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…
… 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…
…objections and interposing appropriate privileges are demanded by the Rules of Civil Procedure. Plaintiff’s hyperbole regarding “stonewalling” and un-reasonable delays in discovery should be dismissed. All of the delays could have been prevented had she served Requests for…
…4 on behalf of the defendant Maxwell. We are the movant for the 5 purposes of today's hearing . I filed both a motion to dismiss 6 the complaint, which is based on one claim of defamation, as 7 well…
…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…