…relationship with Prof. Alan Dershowitz. Giuffre correctly identifies Prof. Dershowitz as but one of at least fifty people interviewed for the movie Silenced: Our War on Free Speech (Danger & Play Prods. 2016).4 Silenced included interviews with rabbis, Imams, priests…
…a clip of Dershowitz’s starring role in the film is featured by its promotional website:4 2 See http://www.silencedmovie.com/ (highlighting added). 3 http://www.imdb.com/title/tt6282878/. 4 Id. 2 Cernovich has not be shy…
…promote her fantastical story to the media; second, her tactical plan to bully potential witnesses into silence by inappropriate threat of criminal prosecution. The Court should reject the “non-protective” order proposed by Plaintiff and enter the reasonable, and enforceable…
…not take Ms. Giuffre’s silence on factual assertions irrelevant to the pending dispute as agreement on their veracity. 1 Case 1:15-cv-07433-LAP Document 961 Filed 12/12/18 Page 2 of 9 Indeed, it appears…
…a motion.” See Resp. at 15-18. Her silence is unsurprising because there is no reasonable explanation for the attachment of entire deposition transcripts. The failure to establish that the exhibits are “judicial documents” alone justifies their continued sealing. See…
…interviews and other contacts including ABC News, Sharon Churcher, and her purported work on behalf of Victims Refuse Silence. With regard to Maxwell’s absence of actual malice, any statements attributed to her regarding Ms. Roberts were limited in scope…
…through 12 her attorneys in Florida, called Victims Refuse Silence, and 13 thereby states that any attempt to impugn anything she says is 14 defamation per se. 15 There is no support in the case law for a profession 16…
… Apart from any efforts made by Jeffrey 19 Epstein or agents on behalf of Jeffrey Epstein to silence 20 you or to have you refrain from providing true and 21 accurate information about the interactions that you had 22 with…
…A Defendant, who committed repeated acts of sexual abuse, publicly proclaims the victim is lying to try to deflect attention from the crimes and to bully the victim back into silence. But this story will not end here. Defamation law…
…ongoing litigation, Mr. Edwards purportedly represents Plaintiff with regard to communications with the media, with regards to “Victims Refuse Silence,” and with regards to communications with law enforcement. See Giuffre’s Supplemental Privilege Log at “Log IDs” 1, 9, 12…
…12. We've 11 asked the Court to exclude evidence relating to the tax 12 compliance of Ms. Giuffre's not-for-profit Victims Refuse 13 Silence. Rule 401 is the first rule under which this should be 14 excluded…
…Inc., 288 F.Supp.2d 513, 516 (S.D.N.Y. 2003). Plaintiff nevertheless unsuccessfully attempts to establish a connection between the subject Statement and her “profession” by pointing to her incorporation of the Victims Refuse Silence, Inc. organization. Pl…
…and other direct and consequential damages.” Compl. Count 1 ¶ 19. Further, Plaintiff claims she “incorporated an organization called Victims Refuse Silence, Inc., a Florida not-for- profit corporation” on December 23, 2014, approximately 10 days before the January 3 Statement…
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