…Ms. Maxwell interposed Interrogatories concerning which “false statements” attributed to Ms. Maxwell were “published globally” as contended in paragraph 9 of Count 1 of the Complaint (Interrog. No. 6) and whether Plaintiff has been defamed by anyone other than 1…
…5 In my view, your Honor, there should be -- the parties 6 should identify globally what I would call category one, 7 category two and category three documents. Category one would 8 be non-judicial documents; category two would be…
…claims.”). Interrogatory No. 6. Identify any “false statements” attributed to Ghislaine Maxwell which were “published globally, including within the Southern District of New York” as You contend in paragraph 9 of Count 1 of Your Complaint, including: a. the exact…