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.447706.363.11
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.447706.1073.0
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.447706.1201.10_1
27 pg
…Court addressed. Accordingly, the objection is well founded.
Plaintiff’s tortured explanation about how the question fits into the Court’s Order is nonsense.
16
G. Objection to Question Number 8
“In terms of preparing for this deposition, what…
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.447706.1327.26
27 pg
…the objection is well founded.
Plaintiff’s tortured explanation about how the question fits into the Court’s Order is nonsense.
16
Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 19 of 27…
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.447706.1137.15_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.447706.408.0
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.447706.45.0
17 pg
…simply too
tangential and remote to be relevant even under the most broad definitions of relevance.
Accordingly, Ms. Maxwell’s objection is well founded and should be sustained by the Court.
II. MS. MAXWELL’S SPECIFIC OBJECTIONS ARE PROPER
Ms…
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.447706.185.7
26 pg
…defamed Plaintiffs, they must show that (i)
they conducted an investigation regarding the credibility of Jane Doe #3's allegations against
Dershowitz, and (ii) that the allegations asserted against Dershowitz by Jane Doe #3 were well-
founded. (Dershowitz Mot. to…
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…
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