gov.uscourts.nysd.447706.605.0.pdf PDF
… Case 1:15-cv-07433-LAP Document 605 Filed 02/09/17 Page 2 of 2 5. Attached hereto as Exhibit 3 is the cast list of the movie Silenced: Our War on Free Speech (Danger & Play Prods. 2016)…
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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…
gov.uscourts.nysd.447706.54.0.pdf PDF
…s media exposure, to enhance her marketability, to extract financial gain for herself and her family, and to promote her sham non-profit, Victims Refuse Silence, Inc. 2. No law enforcement agency pursued any criminal charges against Ms. Maxwell, even…
gov.uscourts.nysd.447706.1330.21.pdf PDF
…and deny the allegations as Dershowitz urges and Prince Andrew has. We run the real risk of guilt by silence and that is likely to feed false claims and false suits as we saw with the BBC I advised the…
gov.uscourts.nysd.447706.1327.4.pdf PDF
…statements to the press, in court pleadings, and in sworn testimony at issue in this matter. Mr. Edwards also has knowledge concerning "Victim's Refuse Silence, Inc." 7. Jeffrey Epstein c/o Tonja Haddad Coleman, Esq. 315 SE 7th Street…
gov.uscourts.nysd.447706.79.5.pdf PDF
…Virginia Giuffre Bob Josefsberg, Esq. - Podhurst Orseck, PA, counsel for Virginia Giuffre Katherine W. Ezell, Esq. - formerly, Podhurst Orseck, PA, counsel for Virginia Giuffre Amy Ederi, Esq. - formerly, Podhurst Orseck, PA (not on website) VRS - acronym for “Victims Refuse Silence”
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.447706.156.0.pdf PDF
…is a subsection of items on Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated April 29, 2016 relating to communication regarding Victims Refuse Silence. 10. Attached as Exhibit I is a true and correct copy of the Articles of…
gov.uscourts.nysd.447706.961.0.pdf PDF
…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…
gov.uscourts.nysd.447706.71.6.pdf PDF
…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…
gov.uscourts.nysd.447706.542.0.pdf PDF
…37. Attached as Exhibit JJ (filed under seal) . 38. Attached as Exhibit KK (filed under seal) 39. Attached as Exhibit LL is a true and correct copy of the Victims Refuse Silence, Inc. Articles of Incorporation dated December 23, 2014…
gov.uscourts.nysd.447706.88.0.pdf PDF
…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…
gov.uscourts.nysd.447706.155.0.pdf PDF
…A)(ii) and S.D.N.Y. LCiv.R 26.2(A). V. Business Advice Regarding Victims Refuse Silence is Not Privileged Plaintiff also has logged 28 documents relating to the entity Victims Refuse Silence (“VRS”) Menninger Decl., Ex. H…
gov.uscourts.nysd.447706.25.0.pdf PDF
…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…
gov.uscourts.nysd.447706.689.0.pdf PDF
…explained that although “Baxter focused on the invocation of the privilege by parties, ‘[a] non- party’s silence in a civil proceeding implicates Fifth Amendment concerns to an even lesser degree.’” LiButti, 107 F.3d at 121 (citing RAD Servs.…