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.447706.916.0
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.447706.1332.17
13 pg
…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)…
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.447706.962.0
7 pg
…Order.
INTRODUCTION
The Protective Order requires the destruction or return of all “Confidential”-designated
materials. This action was terminated more than eighteen months ago when the parties reached a
settlement and stipulated to dismissal, and the Court dismissed the case…
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.447706.957.0
13 pg
…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)…
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.447706.965.0
9 pg
…much to everyone's happiness, including the Court's,
14 and was dismissed shortly thereafter. Two times since May we
15 have asked for agreed upon protocol with the plaintiff's
16 counsel to finish up destroying or exchanging-back…
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.447706.57.1
26 pg
…and Sir David
Cairns, Lord Denning M.R. dissenting) dismissed an appeal
by the plaintiff from Donaldson J.'s order.
On appeal by the plaintiff: —
Held, allowing the appeal, that the due administration of
justice strongly required that a document…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…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…
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.447706.132.1
31 pg
…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 …
giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…e.g., if the case is
settled and dismissed with prejudice before it ever rules on the motion, then the court
is not performing and never has performed a judicial function as to that motion.
Therefore it is not a…