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.447706.165.0
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.447706.363.6
15 pg
…that is irrelevant to this case, in the hopes of being able to intimidate Jane Doe
No. 3 with the press and generate a claim against her. Considering the extensive abuse that Jane
Doe No. 3 suffered as a minor…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…the police reports demonstrate Plaintiff’s tumultuous
home life, bearing no relationship to any press statements or alleged defamation and providing
alternative causation to any of Plaintiff’s now-claimed emotional distress. It makes perfect sense
that Plaintiff would want…
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.447706.1325.1
21 pg
…Churcher is the only person with
much of the information that will prove the truth defense.
The alleged defamatory press release at issue in this case states:
“Each time the story is re told it changes with new salacious details…
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.447706.1330.22
22 pg
…I make and the complaints too
Perhaps we make a statement of the legal risk of saying anything for potential defamation or something that
prevents a full and frank detailed rebuttal + the press not being the place for that…
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.447706.1328.40
3 pg
…column. It's called 'pure favor time' to Emily from the owner of the item, plus the press person wh
may or may not elect to pop it into print.
I certainly do feel that down the long, winding road…
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.447706.1331.29
4 pg
…Ms. Maxwell is the Defendant and may have knowledge concerning matters at
issue, including the events of 1999-2002 and the publication of statements in the
press in 2011-2015.
2. Virginia Lee Roberts Giuffre
c/o Sigrid S. McCawley…
giuffre-maxwell
gov.uscourts.nysd.447706.24.3
3 pg
…the same.
“Miss Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British press and
elsewhere and reserves her right to seek redress at the repetition of such claims.”
Maxwell, a former student at Balliol College…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.40
19 pg
…Ms. Maxwell is the Defendant and may have knowledge concerning matters at
issue, including the events of 1999-2002 and the publication of statements in the
press in 2011-2015.
2. Virginia Lee Roberts Giuffre
c/o Sigrid S. McCawley…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…the publicly filed false affidavits in
prior litigation concerning Intervenor) and then shield from disclosure all proof that the
accusation is perjurious (as she has done previously in this case by designating her book
manuscript and emails to the press…
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
1320-40
19 pg
…Ms. Maxwell is the Defendant and may have knowledge concerning matters at
issue, including the events of 1999-2002 and the publication of statements in the
press in 2011-2015.
2. Virginia Lee Roberts Giuffre
c/o Sigrid S. McCawley…
giuffre-maxwell
gov.uscourts.nysd.447706.363.0
18 pg
…girls.
The allegation is utterly false—a fabrication from start to finish—but, because I am a
well-known law professor and lawyer, it has been widely covered and repeated in the press, both
here and around the world. See …
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…