giuffre-maxwell
gov.uscourts.nysd.447706.1218.31
10 pg
…wexner-israel-fellowship-program), which brings ten
Israeli public officials to Harvard for a fully funded Master’s degree program in public administration at the Kennedy School of
Government.
With the participation of The Wexner Foundation, Republican pollster and rightwing…
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.447706.363.11
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.447706.1320.18
40 pg
…do acknowledge that the
public filing in the Crime Victims’ Rights Act case of their client’s allegation against Defendant
Dershowitz became a major distraction from the merits of the well-founded Crime Victims’
Rights Act by causing delay and…
giuffre-maxwell
gov.uscourts.nysd.447706.1105.0
8 pg
…7
(quotation marks and citation omitted). The Court concluded that Mr. Dershowitz’s
proffered bases for modification – even if well-founded, which the Court rightly
doubted – were beside the point: “That is all well and good, but while fostering
judicial…
giuffre-maxwell
gov.uscourts.nysd.447706.1073.0
22 pg
…the Sealed Materials,
that alone is a violation of the Protection Order.
As Plaintiff well knows, Ms. Maxwell was forced to answer substantial, numerous, ill-
founded questions regarding her private life, her , her
residences, her friends, and her living arrangements…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.4_1
29 pg
…their client’s claims – were false. The Complaint by Edwards and Cassell alleged that
“[i]mmediately following the filing of what Dershowitz knew to be an entirely proper and well-
founded pleading, Dershowitz initiated a massive public media assault on…
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
…se by claiming
9 her profession is as a professional victim. In other words,
10 ten days before she claims my client made statements about her,
11 plaintiff founded a nonprofit through her organization, through
12 her attorneys in Florida…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…privilege. The conduct of the attorneys Edwards and Cassell that forms the basis for
Dershowitz's counterclaim for defamation is nothing more than filing a well-founded motion in
pending federal court proceedings on behalf of pro bono clients. In…
giuffre-maxwell
gov.uscourts.nysd.447706.164.0
29 pg
…their client’s claims – were false. The Complaint by Edwards and Cassell alleged that
“[i]mmediately following the filing of what Dershowitz knew to be an entirely proper and well-
founded pleading, Dershowitz initiated a massive public media assault on…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.18
23 pg
…se by claiming
9 her profession is as a professional victim. In other words,
10 ten days before she claims my client made statements about her,
11 plaintiff founded a nonprofit through her organization, through
12 her attorneys in Florida…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.14_2
40 pg
…do acknowledge that the
public filing in the Crime Victims' Rights Act case of their client's allegation against Defendant
Dershowitz became a major distraction from the merits of the well-founded Crime Victims'
Rights Act by causing delay and…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…24(a) (mandatory intervention)
and 24(b) (permissive intervention). Neither argument for intervention is well-founded.
I. DERSHOWITZ’S ALLEGED “REPUTATIONAL” INTERESTS DO NOT
SATISFY RULE 24(A)’S REQUIREMENTS FOR INTERVENTION AS OF
RIGHT.
Dershowitz first claims that he…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.13
15 pg
…Thus, the
notion that Churcher may be compelled to testify simply because she “observed” firsthand some
of the events about which Maxwell is inquiring in this civil case is not well founded.
In any event, the various accusations of Churcher…
giuffre-maxwell
1320-18
40 pg
…do acknowledge that the
public filing in the Crime Victims’ Rights Act case of their client’s allegation against Defendant
Dershowitz became a major distraction from the merits of the well-founded Crime Victims’
Rights Act by causing delay and…
giuffre-maxwell
gov.uscourts.nysd.447706.408.0
13 pg
…the public filing in the Crime Victims’
Rights Act case of their client’s allegation against Defendant Dershowitz became a major
distraction from the merits of the well-founded Crime Victims’ Rights Act by causing delay and,
as a consequence…
giuffre-maxwell
gov.uscourts.nysd.447706.185.8
24 pg
…any investigation of the credibility of the accusations, and of having acted unethically
…” – even though Dershowitz “knew [the filing in the Federal Action containing the allegations
about Dershowitz] to be an entirely proper and well-founded pleading.” See Compl. …
giuffre-maxwell
gov.uscourts.nysd.447706.1330.1
13 pg
…the public filing in the Crime Victims’
Rights Act case of their client’s allegation against Defendant Dershowitz became a major
distraction from the merits of the well-founded Crime Victims’ Rights Act by causing delay and,
as a consequence…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.45
13 pg
…the public filing in the Crime Victims’
Rights Act case of their client’s allegation against Defendant Dershowitz became a major
distraction from the merits of the well-founded Crime Victims’ Rights Act by causing delay and,
as a consequence…
giuffre-maxwell
gov.uscourts.nysd.447706.561.0
22 pg
…for joinder:
Immediately following the filing of what the Defendant, DERSHOWITZ, knew to be
an entirely proper and well-founded pleading, DERSHOWITZ initiated a massive
public media assault on the reputation and character of BRADLEY J. EDWARDS
and PAUL G…
Comments