giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…Alan Dershowitz, defamed them by
repeatedly claiming in worldwide media broadcasts and other widely-disseminated statements
that they had engaged in conspiring with their client to make up sexual abuse allegations against
Dershowitz. The pleadings and discovery taken to date…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.14
6 pg
…girls
who alleged sexual abuse by Epstein and others in his circle. Giuffre alleged that Epstein's ex-girlfriend Ghislaine Maxwell, daughter of the
late media tycoon Robert Maxwell, abused her. Ghislaine Maxwell has denied allegations of enabling abuse.
Epstein…
giuffre-maxwell
gov.uscourts.nysd.447706.22.0
14 pg
…Maxwell. For years, Ms. Maxwell has
suffered Plaintiff’s unabated and unfiltered character attacks in both the media and in thinly-
veiled press releases masquerading as legal pleadings. Now, Ms. Maxwell has moved to dismiss
the Complaint with the hopes…
giuffre-maxwell
gov.uscourts.nysd.447706.156.0
3 pg
…Giuffre's
Revised Supplemental Privilege Log dated April 29, 2016 relating to media issues and press
releases.
Case 1:15-cv-07433-LAP Document 156 Filed 05/20/16 Page 2 of 3
4. Attached as Exhibit C is…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…audio tapes, photographs or any other print or
electronic media relating to females under the age of 18 from the period of 1999 – present.
a. Maxwell’s Response:
Maxwell objects to this Request on the grounds that it is overly…
giuffre-maxwell
gov.uscourts.nysd.447706.156.1
26 pg
…McCawley, Henderson and defense/commo
20 3/13/2015 17:29 Stan Pottinger [email protected] htojustice.com Pottinger re legal advice on media issues n interest Withheld 2 msg
…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.3
27 pg
…McCawley, Henderson and defense/commo
20 3/13/2015 17:29 Stan Pottinger Jane Doe 2 thtojustice.com Pottinger re legal advice on media issues n interest Withheld 2 msg
…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.15
27 pg
…McCawley, Henderson and defense/commo
20 3/13/2015 17:29 Stan Pottinger [email protected] thtojustice.com Pottinger re legal advice on media issues n interest Withheld 2 msg
…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…ties and is 'part of a very large and close family'.
He said: 'Our client is not Jeffrey Epstein, and she has been the target of endless media
spin', leading prosecutor Moe to later shoot back: 'These are the facts…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.7
29 pg
…in that litigation.
! Request 30 – Ms. Ransome testified that she does not have a current account on Twitter
or any other social media platform, and does not have the information for any for the
years 2006-2007. See Pottinger Dec…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…the police report
will presumably be supplied by Defendant. Indeed, Defendant and/or her joint defense partners
have already made it known to the media that this very police report concerns Ms. Giuffre, see
2
This plan was admitted by…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
…her computer.
17 Requests 21 and 22 relate to her contracts.
18 THE COURT: Yes.
19 MS. MENNINGER: Request 30 is social media.
20 Your Honor, those are the subpoena issues.
21 THE COURT: But how is it relevant here…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.3
26 pg
…January, 2015 press statement.
4. All newspaper or other media where Ghislaine Maxwell's press release appears
5. All evidence obtained by the Federal Bureau of Investigations which relate in any way
to Jeffrey Epstein or Ghislaine Maxwell.
6. All…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…to conceal these facts, other media reports suggest that
the reason that Defendant was trying to sell her townhouse “quietly” was perhaps “to put some
distance between herself and Epstein, who owns a mansion a few blocks away.”
http://pagesix…
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…audio tapes, photographs or any other print or electronic media relating to
females under the age of 18 from the period of 1999 – present.
DOCUMENT REQUEST NO. 8
All documents relating to your travel from the period of 1999 – present…
giuffre-maxwell
gov.uscourts.nysd.447706.1334.1
29 pg
…in that litigation.
! Request 30 – Ms. Ransome testified that she does not have a current account on Twitter
or any other social media platform, and does not have the information for any for the
years 2006-2007. See Pottinger Dec…
giuffre-maxwell
1320-15
27 pg
…McCawley, Henderson and defense/commo
20 3/13/2015 17:29 Stan Pottinger [email protected] thtojustice.com Pottinger re legal advice on media issues n interest Withheld 2 msg
…
giuffre-maxwell
gov.uscourts.nysd.447706.45.0
17 pg
… Request No. 7: All video tapes, audio tapes, photographs or other print or
electronic media relating to females under the age of 18 from the period of 1999-
present.
This request appears to cover books, DVDs, CDs, personal photographs and…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.1
13 pg
…to existing issues).
11. After the motion was filed, various news organizations published articles about it.
Dershowitz also made numerous media statements about the filing, including calling Jane Doe
No. 3 “a serial liar” who “has lied through her teeth…
giuffre-maxwell
gov.uscourts.nysd.447706.165.1
6 pg
…McCawley, Pottinger and BSF staff re
150 2/11/2015 Virginia Giuffre [email protected] media communications. Attorney Client Redacted 3 msg
…