gov.uscourts.nysd.447706.542.8.pdf PDF
…INCORPORATION In compliance with Chapter 617, F. S., ( Not for Profit) ARTICIS I NAME The name of the cQrporation shall be: Victims Refuse Silence, Inc. I ARTICLE H PRINCIPAL OFFICE Principal…
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gov.uscourts.nysd.447706.996.0.pdf PDF
…producing no more money, Ms. Giuffre wants to use its information to profit from generating new lawsuits—and media coverage—through her well-worn strategy: Accuse a prominent person of participating in Epstein’s misconduct; if they deny the allegations…
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…
gov.uscourts.nysd.447706.1327.21.pdf PDF
…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…
gov.uscourts.nysd.447706.749.0.pdf PDF
…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…
gov.uscourts.nysd.447706.1201.20.pdf PDF
…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…
gov.uscourts.nysd.447706.1327.12.pdf PDF
…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…
gov.uscourts.nysd.447706.68.0.pdf PDF
…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 …
gov.uscourts.nysd.447706.599.0.pdf PDF
…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…
gov.uscourts.nysd.447706.1327.9.pdf PDF
…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…
gov.uscourts.nysd.447706.562.1.pdf PDF
…2014, Giuffre incorporated an organization called Victims Refuse Silence, Inc., a Florida not-for-profit corporation. 25. Giuffre intended Victims Refuse Silence to change and improve the fight against sexual abuse and human trafficking. The goal of her organization was…
gov.uscourts.nysd.447706.230.0.pdf PDF
…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…
gov.uscourts.nysd.447706.509.0.pdf PDF
…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…
gov.uscourts.nysd.447706.23.0.pdf PDF
… 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…
gov.uscourts.nysd.447706.1.0.pdf PDF
…2014, Giuffre incorporated an organization called Victims Refuse Silence, Inc., a Florida not-for-profit corporation. 25. Giuffre intended Victims Refuse Silence to change and improve the fight against sexual abuse and human trafficking. The goal of her organization was…
gov.uscourts.nysd.447706.320.0.pdf PDF
…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…
gov.uscourts.nysd.447706.24.1.pdf PDF
…2014, Giuffre incorporated an organization called Victims Refuse Silence, Inc., a Florida not-for-profit corporation. 25. Giuffre intended Victims Refuse Silence to change and improve the fight against sexual abuse and human trafficking. The goal of her organization was…
gov.uscourts.nysd.447706.1295.5.pdf PDF
…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…
gov.uscourts.nysd.447706.370.0.pdf PDF
…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…
gov.uscourts.nysd.447706.148.0.pdf PDF
…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…
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