giuffre-maxwell
gov.uscourts.nysd.447706.604.0
11 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.605.0
2 pg
… 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)…
giuffre-maxwell
gov.uscourts.nysd.447706.1284.0
17 pg
…Epstein and Ms. Maxwell.
19 Ms. Ransome also published a book about her experiences called
20 silenced no more and recently published an op-ed in the
21 Washington Post on July 18, 2022, further describing her
22 background and…
giuffre-maxwell
gov.uscourts.nysd.447706.1283.0
17 pg
…Epstein and Ms. Maxwell.
19 Ms. Ransome also published a book about her experiences called
20 silenced no more and recently published an op-ed in the
21 Washington Post on July 18, 2022, further describing her
22 background and…
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.447706.542.8
4 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.21
11 pg
…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…
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.447706.1327.4
4 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.79.5
2 pg
…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”
giuffre-maxwell
gov.uscourts.nysd.447706.49.0
12 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.749.0
9 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.156.0
3 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.961.0
9 pg
…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…
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.447706.1073.0
22 pg
…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…
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.447706.1090.4_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.447706.1320.24
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…