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.447706.1258.0
3 pg
…and unredacted any and all documents that identify the men who abused the girls trafficked
by Jeffrey Epstein and Defendant Maxwell (“the Epstein Client List”).
Sealing those documents violates the rights of the press and of the people at large…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.43
4 pg
…ABC
January 6, 2015 Tuesday
LENGTH: 942 words
HEADLINE: Prince Andrew under pressure as Palace disputes teen sex scandal
claims
REPORTERS: Philip Williams
BODY:
LEIGH SALES, PRESENTER: It's been a few years since Britain's Royal Family has
been…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…particularly in light of
Ms. Giuffre’s punitive damages claim as well as press reports suggesting that the Defendant may
be selling her assets in New York and transferring the money outside the jurisdiction.
Accordingly, Defendant’s motion for a…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…particularly in light of
Ms. Giuffre’s punitive damages claim as well as press reports suggesting that the Defendant may
be selling her assets in New York and transferring the money outside the jurisdiction.
Accordingly, Defendant’s motion for a…
giuffre-maxwell
gov.uscourts.nysd.447706.443.0
4 pg
…of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S NOTICE OF RELATED ACTION IN THE UNITED KINGDOM TO
OBTAIN THE DEPOSITION OF DEFENDANT’S PRESS AGENT, ROSS GOW
Plaintiff, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.590.1
4 pg
…ABC
January 6, 2015 Tuesday
LENGTH: 942 words
HEADLINE: Prince Andrew under pressure as Palace disputes teen sex scandal
claims
REPORTERS: Philip Williams
BODY:
LEIGH SALES, PRESENTER: It's been a few years since Britain's Royal Family has
been…
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.447706.1340.0
1 pg
…PRESKA, Senior United States District Judge:
It has come to the Court’s attention that several articles
have been published in the domestic and international press
asserting that a woman identified as “Banu Kucukkoylu” is “Doe 102”
in this case…
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.447706.54.0
11 pg
…are false. Giuffre’s fantastical claims,
contained in news stories and press-releases masquerading as legal pleadings over the last five
years have been well-crafted with the assistance of high-priced attorneys to facilitate Giuffre’s
media exposure, to…
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.447706.24.0
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.447706.363.6
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.447706.1320.1
2 pg
…statement 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…
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