giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…to ignore both law and facts. The lawyer
victims of Dershowitz's attacks remained temporarily silenced by their personal unwillingness to
abandon their faith in the legal system or the interests oftheir pro bono client. They filed this
action to…
giuffre-maxwell
gov.uscourts.nysd.447706.589.0
24 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.22
22 pg
…tomorrow?
I will speak to Jeffery Epstein's lawyer but JE has a conflict with you and will want your silence as whilst you
are being attacked there is less heat on him.
Either Virginia Roberts is lying or not…
giuffre-maxwell
gov.uscourts.nysd.447706.69.2
21 pg
…the Seventeenth Judicial Circuit, Broward County, Florida, attached
hereto as Exhibit 18.
19. Victims Refuse Silence Articles of Incorporation and Amendment, attached hereto
as Composite Exhibit 19.
20. Victims Refuse Silence By-laws, attached hereto as Exhibit 20.
21. Victims…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…early 2011.
o Paul Cassell and Brad Edwards (along with other Farmer, Jaffe, attorneys)
represented Ms. Giuffre and Victims Refuse Silence, giving advice regarding
Victims Refuse Silence, starting in October, 2014.
o Meg Garvin (law professor at Lewis & Clark Law…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.4_1
29 pg
…Apart from any efforts made by Jeffrey Epstein or agents on behalf of Jeffrey Epstein to
silence you or to have you refrain from providing true and accurate information about the
interactions that you had with Jeffrey Epstein and others…
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…early 2011.
o Paul Cassell and Brad Edwards (along with other Farmer, Jaffe, attorneys)
represented Ms. Giuffre and Victims Refuse Silence, giving advice regarding
Victims Refuse Silence, starting in October, 2014.
o Meg Garvin (law professor at Lewis & Clark Law…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.42
9 pg
…the reason why sexual
abuse victims typically remain silent and the reason why I did for a long time. That
trend should change. I'm not going to be bullied into silence."
Wendy, your thoughts on her response?
MURPHY: Yes…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.7
11 pg
… 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…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.40
19 pg
…press,
in court pleadings, and in sworn testimony at issue in this matter. Mr. Edwards
also has knowledge concerning “Victim’s Refuse Silence, Inc.”
21. Amanda Ellison
Address unknown at this time
561-628-4338
Ms. Ellison has knowledge concerning…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.18
23 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…concerning, relating or referring to Jeffrey
Epstein, Ghislaine Maxwell or any of their agents or associates.
33. All Documents concerning or relating to Victims Refuse Silence, the organization
referred to in the Complaint, including articles of incorporation, any financial records…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.31
10 pg
…up in 2006, Epstein’s team went on the offensive, bullying and harassing witnesses,
victims and their families into silence.
Going far beyond the typical role of a lawyer, Dershowitz mobilized a pre-emptive smear campaign against the victims, mining
…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.4
35 pg
…iPhone
GIUFFRE005611
CONFIDENTIAL
Case 1:15-cv-07433-LAP Document 1326-4 Filed 01/04/24 Page 8 of 35
From: Jane Doe 2 on behalf of S…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.3
26 pg
…Broward County, Florida, attached
hereto as Exhibit 18.
19. Victims Refuse Silence Articles of Incorporation and Amendment, attached hereto
as Composite Exhibit 19.
20. Victims Refuse Silence By-laws, attached hereto as Exhibit 20.
20
…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…the individual names of Hilary’s
Special Agent Officers involved in intimidating her. She was then forced against her will to sign a
legally binding confidentially agreement on Hilary’s behalf for her eternal silence. If she breaks this
agreement…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.39
35 pg
…iPhone
GIUFFRE005611
CONFIDENTIAL
Case 1:15-cv-07433-LAP Document 1320-39 Filed 01/03/24 Page 8 of 35
From: [email protected] on behalf of Sh…
giuffre-maxwell
gov.uscourts.nysd.447706.20.0
26 pg
…for a stay of all discovery pending
her Motion to Dismiss.
Defendant’s public, defamatory attack on Ms. Giuffre is an unabashed effort to bully this
sexual assault victim into silence. This is an old story. Defendant is calling Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.99.0
22 pg
…that an agency
claiming some special governmental-public interest ‘cone of silence’ demonstrate the specific
public interest that would be jeopardized by an otherwise customary exchange of information.”).
Plaintiff as a private party has no right to invoke the public…