giuffre-maxwell
gov.uscourts.nysd.447706.1295.14
6 pg
…was also a pedophile, accused of recruiting dozens of underage girls into a sex-slave network, buying their
silence and moving along, although he has been convicted of only one count of soliciting prostitution from a minor. Visitors to his…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.5
161 pg
…has rounded on her accusers, insisting that her portrayal as a
‘cartoon caricature of a villain’ is utterly false
Breaking a year-long silence since Epstein’s death, sources close to Maxwell have gone on
the offensive to put her…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…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…
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.447706.1320.24
16 pg
…11) Ms. Boylan; and (12) the 30(b)(6) witness for Victims Refuse
Silence.
7
Defendant has unilaterally scheduled - without consulting counsel for Ms. Giuffre - at least two
of these depositions for days when depositions of Ms. Giuffre’s witnesses…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.17_1
16 pg
…Churcher; (11 )- -; and (12) the 30(b)(6) witness for Victims Refuse
Silence.
7
Defendant has unilaterally scheduled - without consulting counsel for Ms. Giuffre - at least two
of these depositions for days when depositions of Ms. Giuffre's witnesses have…
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.447706.1320.40
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.447706.1137.16_2
15 pg
…Chmcher; ; and (12) the 30(b)(6) witness for Victims Refuse
Silence.
6
Defendant has unilaterally scheduled - without consulting counsel for Ms. Giuffre - at least two
of these depositions for days when depositions of Ms. Giuffre's witnesses have been…
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.447706.562.1
13 pg
…also
suffered from sexual trafficking and abuse.
24. On December 23, 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
…
giuffre-maxwell
gov.uscourts.nysd.447706.78.0
30 pg
…Indeed, Ms. Giuffre has produced her
copyright protected material, her communications with journalists and literary agents, and her
documents concerning her charity, Victims Refuse Silence. Additionally, Ms. Giuffre has
produced her personal healthcare files, private communications with family members, and…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.21
15 pg
…11) Ms. Boylan; and (12) the 30(b)(6) witness for Victims
Refuse Silence.
6
Defendant has unilaterally scheduled - without consulting counsel for Ms. Giuffre - at least two
of these depositions for days when depositions of Ms. Giuffre’s witnesses…
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.447706.23.0
32 pg
…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…
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…
giuffre-maxwell
1320-21
15 pg
…11) Ms. Boylan; and (12) the 30(b)(6) witness for Victims
Refuse Silence.
6
Defendant has unilaterally scheduled - without consulting counsel for Ms. Giuffre - at least two
of these depositions for days when depositions of Ms. Giuffre’s witnesses…
giuffre-maxwell
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
1320-24
16 pg
…11) Ms. Boylan; and (12) the 30(b)(6) witness for Victims Refuse
Silence.
7
Defendant has unilaterally scheduled - without consulting counsel for Ms. Giuffre - at least two
of these depositions for days when depositions of Ms. Giuffre’s witnesses…