giuffre-maxwell
gov.uscourts.nysd.447706.24.3
3 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.919.0
2 pg
…District Court
Southern District of New York
VIRGINIA GIUFFRE,
Plaintiff,
v. usuc .
DO UMENT
…
giuffre-maxwell
gov.uscourts.nysd.447706.29.0
2 pg
…GIUFFRE,
PLAINTIFF, DEFENDANT’S NOTICE OF
V. SUPPLEMENTAL AUTHORITY
GHISLAINE MAXWELL, …
giuffre-maxwell
gov.uscourts.nysd.447706.916.0
2 pg
…RWS Document 916 Filed 05/24/17 Page 1 of 2
United States District Court
Southern District of New York
VIRGINIA GIUFFRE,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
GHISLAINE MAXWELL,
Defendant.
________________…
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.447706.113.0
3 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.116.0
6 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.29.1
18 pg
…Plaintiff in a false light, and (3) Defendant intentionally inflicted emotional distress upon
Plaintiff.1 Presently before the Court is a Motion to Dismiss and Brief in Support filed by
Defendant alleging that no justiciable claim or controversy exists. Doc…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.1
18 pg
…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…
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.447706.538.0
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.447706.931.0
15 pg
…you. All of these documents are clearly
9 eventually subject to discovery in the other case. They're all
10 relevant to the motion to dismiss. We provided you with a --
11 THE COURT: Thank you very much.
12 MR…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.13_1
19 pg
…in this case. That testimony has no bearing on the issue of whether Plaintiff violated a Court Order to
produce medical records (indeed none of the witnesses discussed know a single thing about Plaintiff’s medical
conditions), and Plaintiff’s…
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.447706.26.1
26 pg
…08/16 Page 2 of 26
Green v. Cosby, --- F.Supp.3d ---- (2015)
[7]
dismissal on basis of self-defense privilege was not
2015 WL 5923553 warranted.
Only the We…
giuffre-maxwell
gov.uscourts.nysd.447706.269.0
19 pg
…in this case. That testimony has no bearing on the issue of whether Plaintiff violated a Court Order to
produce medical records (indeed none of the witnesses discussed know a single thing about Plaintiff’s medical
conditions), and Plaintiff’s…
giuffre-maxwell
gov.uscourts.nysd.447706.1005.0
6 pg
…a hope
of judicial attention, it surely is disqualified when, as here, all hope is lost—the case is settled,
dismissed with prejudice, and closed years ago. It may retain its status as a filed document, but
it is not…
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