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.447706.590.1
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.447706.1331.19
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.447706.996.0
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.447706.1328.20
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.447706.1331.27
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.447706.1331.23
4 pg
…I am happy to
6 testify. I cannot testify to what somebody
7 else did or didn't do.
8 Q. Did you issue a statement to your
9 press agent, Ross Gow in 2015, stating that
10 Virginia Roberts'…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…that substantial portions of her story are untrue; she has so far
refused to say under oath what other lies printed by the press about her story are untrue, but has
admitted that journalist Sharon Churcher “got it wrong.” For…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.10
6 pg
…I am happy to
6 testify. I cannot testify to what somebody
7 else did or didn't do.
8 Q. Did you issue a statement to your
9 press agent, Ross Gow in 2015, stating that
10 Virginia Roberts'…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.19
15 pg
… That's not a
24 diary. It was just a book she was writing
25 that you helped sell to the press, as if it
MAGNA& LEGAL SERVICES
Case 1:15-cv-07433-LAP Document 1330-19 Filed 01/05…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.26
27 pg
…that substantial portions of her story are untrue; she has so far
refused to say under oath what other lies printed by the press about her story are untrue, but has
admitted that journalist Sharon Churcher “got it wrong.” For…
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.447706.1331.29
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.447706.1320.40
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.447706.748.5
2 pg
…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 old
defamatory claims.
Sent from my BlackBerry° wireless device
GM_ 00068
giuffre-maxwell
gov.uscourts.nysd.447706.1330.8
10 pg
…of
discovery, and after Defendant’s second deposition was taken, Defendant produced two critical
documents which were e-mail communications: one between her and her press agent, Ross Gow,
and another between her and her former boyfriend, convicted pedophile Jeffrey…
giuffre-maxwell
gov.uscourts.nysd.447706.751.1
2 pg
…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 old
defamatory claims.
Sent from my BlackBerry° wireless device
GM_ 00068
giuffre-maxwell
gov.uscourts.nysd.447706.515.0
12 pg
…Plaintiff’s Joinder Motion was followed three days later by the denial of Ms. Maxwell’s
press agent that forms the basis of this defamation action.). While the present defamation action
may not have accrued at the time she destroyed…
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