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.447706.443.0
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.447706.1325.1
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.447706.1330.21
11 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…
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.447706.1328.40
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.447706.1330.23
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.447706.1332.16
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.447706.79.1
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.447706.29.0
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.447706.82.0_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.447706.1218.9
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.447706.1020.0
7 pg
…and files. Courts must exercise their
supervisory power over their own records and files to ensure they “‘are not used to
gratify private spite or promote public scandal” or “serve as reservoirs of libelous
statements for press consumption.’” Brown, 929…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.10
469 pg
…That was on my partner's
25 cell phone.
Highly Confidential
Page 42
1 HIGHLY CONFIDENTIAL AEO
2 Q. And what had you read in the
3 press that caused you to get in touch
4 with Ms. Callahan…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…Defendant’s documents concerning Ms. Giuffre are directly
relevant to this action, particularly because Defendant has created multiple drafts of statements to
the press defaming Ms. Giuffre.
Throughout the months of motion practice concerning these issues, and throughout all of…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…Defendant’s documents concerning Ms. Giuffre are directly
relevant to this action, particularly because Defendant has created multiple drafts of statements to
the press defaming Ms. Giuffre.
Throughout the months of motion practice concerning these issues, and throughout all of…
giuffre-maxwell
gov.uscourts.nysd.447706.343.0
8 pg
…8
position in this case, including, sharing the same attorney. Defendant is presumably aware of
everything that her press agent will say.2
If Defendant truly needs to secure a rebuttal witness, she knows, right now, who any such
witness…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.19
21 pg
…Defendant’s documents concerning Ms. Giuffre are directly
relevant to this action, particularly because Defendant has created multiple drafts of statements to
the press defaming Ms. Giuffre.
Throughout the months of motion practice concerning these issues, and throughout all of…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.13
35 pg
…That was on my partner's
25 cell phone.
Highly Confidential
Page 42
1 HIGHLY CONFIDENTIAL AEO
2 Q. And what had you read in the
3 press that caused you to get in touch
4 with Ms. Callahan…
giuffre-maxwell
gov.uscourts.nysd.447706.218.0
25 pg
…Civ. Rights Law § 79-h (“Section 79-h”).1 That statute, which stems
from the First Amendment and the press clause of the New York State constitution (art. I, § 8),
provides reporters with an absolute privilege against disclosure of any…
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