gov.uscourts.nysd.447706.1200.14_1.pdf PDF
…him a Page 270 1 G Maxwell - Confidential 2 A. She helps with my not-for-profit 3 ocean foundation and any other related 4 activities that I may have. 5 Q. Is she paid for by Jeffrey Epstein…
…him a Page 270 1 G Maxwell - Confidential 2 A. She helps with my not-for-profit 3 ocean foundation and any other related 4 activities that I may have. 5 Q. Is she paid for by Jeffrey Epstein…
…4 of 11 Page 270 1 G Maxwell - Confidential 2 A. She helps with my not-for-profit 3 ocean foundation and any other related 4 activities that I may have. 5 Q. Is she paid for by Jeffrey Epstein…
…1305 (5th Cir. 1991) .................................... 8 Parsons v. Honeywell, Inc., 929 F.2d 901, 907 (2d Cir.1991) .................................................... 6-7 Spanierman Gallery, Profit Sharing Plan v. Merritt, No. 00CIV5712LTSTHK, 2003 WL 22909160, at *5 (S.D.N.Y. Dec. 9, 2003)…
…20 12. Victims Refuse Silence is a sham not-for-profit established to create a claim for defamation per se (Motion in Limine 12)...................................................................... 20 i Case 1:15-cv-07433-LAP Do…
…and Defendant has provided no evidence other than the fact of his representation of Plaintiff ' s non - profit to doubt that the communications logged are privi l eged. Having provided no grounds to doubt the sworn representations of Plaintiff ' s…
…Plaintiff’s proposal included astoundingly broad terms, to wit: x “Terramar” -- both the name of Ms. Maxwell’s non-profit and x x x “max*” – part of Ms. Maxwell’s last name, as well as all of her paternal relatives…
…citation omitted). “In assessing the amount of damages to award for defamation, a jury is not limited to compensating the plaintiff for ‘economic’ losses, such as demonstrable lost profits. Rather, a plaintiff may suffer ‘non-economic’ injuries as well. Among …
…injuries. In contrast, Taylor does not offer opinions that fall within the competence of an accountant, such as financial reports and loss/profit ledgers. Instead, he ventures far afield . Such is the stuff of an attorney’s closing argument, not…
…Giuffre publicly and falsely accused Professor Dershowitz of sex crimes, then spent years attempting to profit from those allegations and disseminate them as widely as possible. She now seeks to hijack this Court’s Article III powers to hamstring Professor…
…case, and Defendant has provided no evidence other than the fact of his representation of Plaintiff's non-profit to doubt that the communications logged are privileged. Having provided no grounds to doubt the sworn representations of Plaintiff's counsel…
…been produced. Plaintiff also produced an email to but not any response to that email. The iCloud account also discloses a previously undisclosed potential witness, , a person working at a not-for-profit relating to sexual trafficking victims. Apparently, in…
…at 86, since it is difficult to prove what is contained in documents that have been destroyed. To require a detailed showing in such circumstances poses the danger that “the spoliator [may] profit from its” own misconduct. Id. (quoting Orbit…
… Defendant’s defamatory statements “tended to injure Giuffre in her professional capacity as the president of a non-profit corporation designed to help victims of sex trafficking, inasmuch as they destroyed her credibility and reputation among members of the…
…wit: Plaintiff’s originally proposed search terms would literally hit on every single email from either Ms. Maxwell’s personal or her business email addresses, as well as every document related to the non-profit, The Terramar Project, that Ms…
…evidentiary, as to the facts alleged in the pleading.” 2 In actuality, it appears that the very purpose of Plaintiff’s inclusion in the CVRA action of explicitly detailed allegations of sexual interaction with high profile individuals including Ms. Maxwell…
…MS. MAXWELL’S PERSONAL AND FINANCIAL INFORMATION ARE IRRELEVANT TO THIS ACTION At issue here are requests for literally every piece of financial information regarding Ms. Maxwell and any company or non-profit in which she holds an interest, including…
…Maxwell knows by whom she is being falsely accused. Plaintiff is not a Good Samaritan witness. She has sought and seeks to profit from her wild accusations. As such, she has no credible claim to privacy or that society has…
…be revealed to the public to advance her non-Rule 56- related ulterior purposes, including the purpose of gaining publicity and notoriety and creating an environment in which she could continue to profit from her allegations.” Case No. 18-2868…
…MS. MAXWELL’S PERSONAL AND FINANCIAL INFORMATION ARE IRRELEVANT TO THIS ACTION At issue here are requests for literally every piece of financial information regarding Ms. Maxwell and any company or non-profit in which she holds an interest, including…
…23 Produce all W-2s, K-1s, and any other documents reflecting any income (including salary, bonuses, dividends, profit distributions, royalties, advances, annuities, and any other form of income), including all gross and net revenue received by You directly or…
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