giuffre-maxwell
gov.uscourts.nysd.447706.1201.26
28 pg
… Show Paris mastermind's reassure over
All aboard the 'Lolita Express': Flight logs Site Web Enter your search
reveal the many trips Bill Clinton and Alan
Dershowitz took on pedophile Jeffrey
Epstein's private jet wit…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.1
8 pg
…Accordingly, Ms. Maxwell
requests that the Court exercise its express power under Local Criminal Rule 23.1(h) and enter
an Order requiring compliance with that rule to prevent further unwarranted and prejudicial
pretrial publicity by the Government, its agents…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.17
12 pg
…at Exhibit 10, “All aboard the ‘Lolita Express’: Flight logs reveal the
many trips and Alan Dershowitz took on pedophile Jeffrey Epstein’s private jet with
anonymous women” at The Daily Mail, http://www.dailymail.co.uk/news/article-
2922773…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.14
6 pg
…Flight logs show that from 2001 to
2003, Bill Clinton flew on Epstein's private plane, dubbed "The Lolita Express" by the press, 26 times. After Epstein's arrest in July 2006,
federal tax records show Epstein donated $25,000…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…Virginia Giuffre in separate pending
matters, and shall continue to advance her legitimate legal interests in those matters. As
expressly understood by the parties upon the execution of the Confidential Settlement
Agreement and Mutual Release, Ms. Giuffre reaffirms her allegations…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.22_1
12 pg
…down and sat in the stool
10 exactly the way the girls that I mentioned to
11 you sat at Jeffrey's house, with no
12 expression and with their head down. But we
13 could tell that she was…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.17
12 pg
…down and sat in the stool
10 exactly the way the girls that I mentioned to
11 you sat at Jeffrey's house, with no
12 expression and with their head down. But we
13 could tell that she was…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.2
70 pg
…delete it from your system. Please
be advised that the views and opinions expressed in this e-mail may not
reflect the views and opinions of Associated Newspapers Limited or any of
its subsidiary companies . We make every effort to…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…J).
Without waiver of the foregoing, Ms. Maxwell responds as follows:
Ms. Maxwell retains her First Amendment privilege to express her opinion, to criticize others
including Plaintiff, and to comment on matters of public interest, including Plaintiff’s allegations
of…
giuffre-maxwell
gov.uscourts.nysd.447706.1285.0
6 pg
…parte submissions. If this Court,
in fact, permits the Non-Party Does to express their privacy concerns on an ex parte
basis to avoid making additional harmful disclosures to the adverse parties,
intervenors, and other potential bad actors, then Doe…
giuffre-maxwell
gov.uscourts.nysd.447706.1286.0
6 pg
…parte submissions. If this Court,
in fact, permits the Non-Party Does to express their privacy concerns on an ex parte
basis to avoid making additional harmful disclosures to the adverse parties,
intervenors, and other potential bad actors, then Doe…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…requesting
your Stipulation to the adding of Jane Doe #[3] as well. Her true name is
[redacted].… As we expressed in our personal meetings a couple years ago, we
don’t understand the tactical decision to be adversarial to…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.19
4 pg
…have sued Dershowitz for defamation after he alleged they should be
disbarred for initially putting Roberts' allegations in court papers.
"I am happy today to express my willingness to be deposed after the three of them are deposed," he said…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.7
12 pg
…12
proceedings (apparently, also forgetting the 23 flights she shared with Ms. Giuffre on Epstein’s
private jet,6 known colloquially as the “Lolita Express”7).
Police Detective Joseph Recarey, who led the investigation of Epstein, testified that
Defendant procured…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.30
40 pg
…and sat in the stool
10 exactly the way the girls that I mentioned to
11 you sat at Jeffrey's house, with no
12 expression and with their head down. But we
13 could tell that she was very…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.22
40 pg
…and sat in the stool
10 exactly the way the girls that I mentioned to
11 you sat at Jeffrey's house, with no
12 expression and with their head down. But we
13 could tell that she was very…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.7
9 pg
…person described in and who executed the
foregoing instrument and acknowledged to and
16 before me that he executed the said instrument
in the capacity and for the purpose therein
17 expressed.
18
19 Witness my hand and official seal …
giuffre-maxwell
gov.uscourts.nysd.447706.1199.18_1
40 pg
…and sat in the stool
10 exactly the way the girls that I mentioned to
11 you sat at Jeffrey's house, with no
12 expression and with their head down. But we
13 could tell that she was very…
giuffre-maxwell
gov.uscourts.nysd.447706.20.0
26 pg
…441, 516 N.Y.S. 2d 234, 234 (1987) (“inasmuch as the defendant Dr. Weintraub
accused the plaintiff of personal dishonesty, the allegedly libelous statements are not
constitutionally protected expressions of opinion”); Mase v. Reilly, 206 A.D. 434, 436…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…enters the public record.
Brown, 929 F.3d at 47 (internal quotation omitted).
The media coverage over the course of the previous weeks bears out – powerfully – the
concerns expressed by the Court of Appeals. A review of media reporting from…
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