giuffre-maxwell
gov.uscourts.nysd.447706.1090.28_4
5 pg
…January 21, 20l51Z:O1PK4
To: Gmax
I have never been a party in any criminal action pertaining to JE
Every story in the press innuendo and comment has been taken from civ
depositions against JE, which were settled many years…
giuffre-maxwell
gov.uscourts.nysd.447706.981.0
2 pg
…the
Maxwell records was to give the Jeffrey Epstein network the attention it deserved. Mr.
Cernovich had informed many members of the press that Epstein had escaped justice,
with little to no interest from them. Other than a May 4…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.19
12 pg
…self-serving
affidavit by her attorney Philip Barden in support of her motion for Summary Judgment that
discussed Mr. Barden’s “intent” in allegedly being the main drafter of Defendant’s January 2,
2015 press release. (DE 586 at p…
giuffre-maxwell
gov.uscourts.nysd.447706.960.0
1 pg
…sealed materials. Because Intervenor Dershowitz has failed to provide any details
whatsoever concerning his allegations (which appear to have been made as part of his press
strategy in responding to public criticism over his work for Jeffrey Epstein), it is…
giuffre-maxwell
gov.uscourts.nysd.447706.24.0
4 pg
…1].
4. Attached hereto as Exhibit 2, is a true and correct copy of the March 9, 2011 Press
Release Statement.
5. Attached hereto as Exhibit 3, is a true and correct copy of the January 3, 2015
Statement issued…
giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…Giuffre and her lawyers, in short, are using the court defamation-proof
submissions in this case as a “reservoir[] of libelous statements” to “gratify private spite or
promote public scandal” and “for press consumption,” Brown v. Maxwell, 929 F.3d…
giuffre-maxwell
gov.uscourts.nysd.447706.1015.0
4 pg
…Pellegrino, 380 F.3d 83, 96 (2d Cir. 2004) (“The docketing of motions to close a
proceeding or seal certain documents provides notice to the public, as well as to the press, that
such a motion has been made and . . …
giuffre-maxwell
gov.uscourts.nysd.447706.1331.27
11 pg
…26(a)(1)(A) Disclosures. The third-listed individual we identified who “likely [has]
discoverable information” was Philip Barden, who, we disclosed, had information “concerning
press statements . . . at issue in this matter”:
3. Philip Barden
Devonshires Solicitors LLP
30 Finsbury…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.38
8 pg
…on privilege, he wagered that the consequences from this Court for his deliberate violation
of the settlement privilege would not be harsh enough to offset the benefit he received by feed ing
fa lse information to the press. On December…
giuffre-maxwell
gov.uscourts.nysd.447706.89.0
10 pg
…school casebook. See Beloof, Cassell & Twist, Victims in Criminal Procedure (3d ed. North
Carolina Academic Press 2010). He has also litigated crime victims’ rights matters before
federal courts around the country, including the United States Supreme Court. See, e.g…
giuffre-maxwell
gov.uscourts.nysd.447706.550.0
3 pg
…540). Sealing these documents violates the rights of the press and of the people at large, as
guaranteed to them under the First Amendment and long-standing traditions of common law
Movant will move this Court for such an order…
giuffre-maxwell
gov.uscourts.nysd.447706.79.1
12 pg
…members of the press present so that you all understand
21 that.
22 The reason we are on the phone is because defense
23 counsel had the good judgment to live in Colorado and because
24 Colorado has been blessed…
giuffre-maxwell
gov.uscourts.nysd.447706.604.0
11 pg
…27, 2017).1 If it was not
newsworthy, it would not have been leaked to the press.
Mr. Cernovich understands the sensitivity of these issues; he has no personal interest in
learning about or exposing what happened to Giuffre or…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.5
4 pg
…Broward County, Florida matter.
14. Attached as Exhibit M is a true and correct copy of the press release issued by the
parties in the Dershowitz Case on April 8, 2016.
15. Attached as Exhibit N is a true and…
giuffre-maxwell
gov.uscourts.nysd.447706.29.0
2 pg
…among other things, that Cosby defamed an alleged sexual
assault victim by issuing statements to the press describing the allegations against him as
“unsubstantiated, fantastical stories…[that] have escalated far past the point of absurdity.” (Ex.
A at 8…
giuffre-maxwell
gov.uscourts.nysd.447706.26.1
26 pg
…not substantially true;
[3]
press release describing plaintiff’s allegation that
[3]
defendant had sexually assaulted her “fabricated or Libel and Slander
unsubstantiated stories,” “ridiculous claims,” and “an What law governs
absurd fabric…
giuffre-maxwell
gov.uscourts.nysd.447706.811.0
2 pg
…evidence is
otherwise discussed in publicly available articles and even the public docket entries in
this case.
Similarly, her arguments over the press release language itself, to whom it was directed,
and the meaning of “malice” are issues of law…
giuffre-maxwell
gov.uscourts.nysd.447706.82.0_2
11 pg
…members of the press present so that you all understand
21 that.
22 The reason we are on the phone is because defense
23 counsel had the good judgment to live in Colorado and because
24 Colorado has been blessed…
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.447706.898.0
4 pg
…be heard is both Constitutionally required and appropriate under
the circumstances.
This case is of obvious, significant public interest, and the events underlying the lawsuit
have been covered extensively in the press, including in the Post and Daily News. However…
Comments