giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…Introduction
Plaintiff cannot meet the merits of Ms. Maxwell’s well-founded objections to the release
her July 2016 compelled deposition testimony or information concerning various Non-Parties, all
of whom relied on the Protective Order issued by the Court…
giuffre-maxwell
gov.uscourts.nysd.447706.29.0
2 pg
…the court dismissed, with prejudice, what it found to be a “very detailed
and complete Complaint1” alleging, among other things, that Cosby defamed an alleged sexual
assault victim by issuing statements to the press describing the allegations against him as…
giuffre-maxwell
gov.uscourts.nysd.447706.22.0
14 pg
…RWS Document 22 Filed 12/15/15 Page 2 of 14
Table of Contents
ARGUMENT....................................................................................................................... 2
I. The Motion to Dismiss is Dispositive and Well Founded In Law ....................…
giuffre-maxwell
gov.uscourts.nysd.447706.26.0
3 pg
…defamation complaint, holding that Cosby’s “suggestion that Plaintiff intentionally lied about
being sexually assaulted” could expose plaintiff to “‘scorn or ridicule,” and, therefore, Cosby’s
statement could be found to have a “defamatory meaning.” Green v. Cosby, No. CV…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.5
4 pg
…New
York.
- - -
MAGNA LEGAL SERVICES
1200 Avenue of the Americas
New York, New York 10026
(866) 624-6221
Confidential
Page 163
1 G. Maxwell - Confidential
2 and foundation.
3 A. Can you re…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.15_1
4 pg
…New
York.
- - -
MAGNA LEGAL SERVICES
1200 Avenue of the Americas
New York, New York 10026
(866) 624-6221
Confidential
Page 163
1 G. Maxwell - Confidential
2 and foundation.
3 A. Can you re…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…acknowledge that the public filing in the Crime Victims’
Rights Act case of their client’s allegations against Defendant Dershowitz became a major
distraction from the merits of the well-founded Crime Victims’ Rights Act case by causing
delay and…
giuffre-maxwell
gov.uscourts.nysd.447706.1059.0
3 pg
…Doc.892, at 4-10. It found that “the
parties and multiple deponents have reasonably relied on the Protective Order in giving
testimony and producing documents including evidence of assault, medical records, and
emails,” and “[t]hird-party witnesses have…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.33
3 pg
…conduct of their Chambers. A copy of the barrister and / or their Chambers’ complaints procedure
may be obtained by contacting the Senior Clerk of that Chambers, whose contact details can be found online, or from us. Complaints may be made…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.27
3 pg
…conduct of their Chambers. A copy of the barrister and / or their Chambers’ complaints procedure
may be obtained by contacting the Senior Clerk of that Chambers, whose contact details can be found online, or from us. Complaints may be made…
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
… What, if anything, were they in
4 response to?
5 Your Honor has found in previous cases, such as
6 Hawkins v. City of New York, that the failure to identify the
7 individuals to whom the statement allegedly was…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.38
8 pg
…s Affidavit (hereinafter "McCawley Affidavit"), and despite this Court' s admonition to
Defendant to cease revealing confidential settlement negotiations tit at tit is Court found to be
confidential and placed under seal, Dershowitz intentionally defied this Court's Order and…
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.447706.1113.0
7 pg
…at 9.) Third, the Court found
that parties providing documents and testimony in Maxwell
reasonably relied on the Maxwell protective order, whose promises
of confidentiality “functioned as a powerful mechanism for
inducing parties to provide …
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.447706.980.0
10 pg
…a) non-judicial records in this matter should remain sealed;
(b) judicial records found to have had only a negligible role in the performance of Article III
duties should likewise remain sealed; and (c) as to all other judicial records…
giuffre-maxwell
gov.uscourts.nysd.447706.958.3
4 pg
…via affidavit
1
Although Mr. Cassell asserted in July 2017, that the matter has not yet been “concluded” given the
pendency of an appeal by intervenors, Judge Sweet found otherwise, i.e., that the case terminated on
May 25, 2017…
giuffre-maxwell
gov.uscourts.nysd.447706.992.0
5 pg
…Bryan, 339 U.S. 323,
331-32 (1950) (elaborating the importance of balancing “the great power of testimonial
compulsion” against exemptions “grounded in a substantial individual interest which has been
found, through centuries of experience, to outweigh the public interest…
giuffre-maxwell
gov.uscourts.nysd.447706.1215.0
13 pg
…insufficient to render that paper
a judicial document subject to the right of public access.” She proclaimed that “[a] review of the
case law reveals that every circuit to have directly addressed this point has found that documents
1
Ms…
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