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.447706.1219.22
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.447706.443.0
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.447706.981.0
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.447706.165.0
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.447706.1015.0
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…
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.447706.1330.21
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.447706.1201.10_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.447706.1330.22
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.447706.1330.19
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.447706.1218.38
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…
Comments