giuffre-maxwell
gov.uscourts.nysd.447706.443.0
4 pg
…agent, Ross Gow, who is a key witness in this case because he issued, on Defendant’s behalf, one
of the defamatory statements at issue to multiple media outlets.
Defendant’s counsel, Philip Barden, is also counsel for Mr. Gow…
giuffre-maxwell
gov.uscourts.nysd.447706.981.0
2 pg
…Case No.: 1:15-cv-07433-LAP
Dear Judge Preska:
Intervenor Michael Cernovich d/b/a Cernovich Media originally sought to intervene and
unseal the wholly-redacted summary judgment documents filed by Defendant Ghislaine
Maxwell and the subsequent summary judgment…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…Docket Entries. ............. 8
A. “Personal” Information in Maxwell’s Deposition Transcript Does Not Warrant
Continued Sealing. .............................................................................................................. 9
B. The Potential for “Media Abuse” Does Not Warrant C…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.23
9 pg
…s long-time boyfriend, convicted pedophile, Jeffrey Epstein. The two
documents at issue in the instant motion are Defendant’s communications with her press agent and
with Epstein concerning potential statements to the media regarding Ms. Giuffre. Therefore, not only
…
giuffre-maxwell
gov.uscourts.nysd.447706.604.0
11 pg
…identifies Prof.
Dershowitz as but one of at least fifty people interviewed for the movie Silenced: Our War on
Free Speech (Danger & Play Prods. 2016).4 Silenced included interviews with rabbis, Imams,
priests, social media personalities, comedians, computer hackers, lawyers…
giuffre-maxwell
gov.uscourts.nysd.447706.492.0
9 pg
…litigation: Defendant’s defamation of
Ms. Giuffre through the media.
1
Case 1:15-cv-07433-LAP Document 492 Filed 10/28/16 Page 2 of 9
p
That is relevant to Ms. Giuffre’s claims for multiple reasons…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…the account let alone the password.
3
By contrast, Ms. Maxwell requested that Plaintiff identify all email and social media accounts which she
had used since 1998. Plaintiff provided false information, and purposefully omitted accounts that have since been
discovered…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…discovery only after resolution
of dispositive motions, and some afford only disclosure of a financial affidavit prior to
dispositive motions. See, e g., Hazeldine v. Beverage Media, Ltd., No. 94 CIV. 3466 (CSH),
1997 WL 362229, at *2-*3 (S…
giuffre-maxwell
gov.uscourts.nysd.447706.1259.0
17 pg
…17
faithfully observing its best traditions, the print and electronic media contributes to public
understanding of the rule of law" and "validates [its] claim of functioning as surrogates for the
public.” Brown, supra at 53 (internal quotation marks and citations…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
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.447706.1328.23
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.447706.53.0
15 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.
Request No. 15: All video tapes, audio tapes, photographs or any…
giuffre-maxwell
gov.uscourts.nysd.447706.561.0
22 pg
…Alan Dershowitz. Thereafter, Dershowitz repeated attacked Edwards
and Cassell’s professionalism in a protracted mass media campaign. Edwards and Cassell
responded to this attack by bringing a Florida state defamation action Dershowitz. As explained in
Edwards and Cassell’s complaint…