giuffre-maxwell
gov.uscourts.nysd.447706.1060.0
2 pg
…Id. at 2. As this Court knows, the Second Circuit spoke directly to the
issues of confidentiality and unsealing of documents in this case and specifically vacated two of
the three decisions cited by Maxwell. Brown v. Maxwell, 929 F…
giuffre-maxwell
gov.uscourts.nysd.447706.79.1
12 pg
…because defense
23 counsel had the good judgment to live in Colorado and because
24 Colorado has been blessed with frequent snow this season and
25 there was, when we last spoke, about the problem of defense
SOUTHERN DISTRICT REPORTERS…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.10
64 pg
…are set for March 13 right now, and
12 we actually had on the agenda, Jeff and I spoke about wanting
13 to talk to you about this today. We had originally anticipated
14 a two-week trial. We have…
giuffre-maxwell
gov.uscourts.nysd.447706.82.0_2
11 pg
…because defense
23 counsel had the good judgment to live in Colorado and because
24 Colorado has been blessed with frequent snow this season and
25 there was, when we last spoke, about the problem of defense
SOUTHERN DISTRICT REPORTERS…
giuffre-maxwell
gov.uscourts.nysd.447706.81.0
1 pg
…error, counsel for Ms. Giuffre spoke with an employee with the
ECF help desk who instructed us to inform the Court via letter that he placed a temporary seal on
Exhibit 4 to Docket Entry 79, Declaration of Sigrid S…
giuffre-maxwell
gov.uscourts.nysd.447706.702.0
63 pg
…are set for March 13 right now, and
12 we actually had on the agenda, Jeff and I spoke about wanting
13 to talk to you about this today. We had originally anticipated
14 a two-week trial. We have…
giuffre-maxwell
gov.uscourts.nysd.447706.24.0
4 pg
…is a true and correct copy of the January 3, 2015
Statement issued by Defendant’s spokesman Ross Gow, quoted in the Express.
1
Case 1:15-cv-07433-RWS Document 24 Filed 12/17/15 Page 2 of…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…with multiple underage girls, Epstein ultimately
pleaded guilty to just a single state charge of soliciting prostitution.)
Case 1:15-cv-07433-LAP Document 363-11 Filed 08/11/16 Page 4 of 40
A spokesman for Boies, Schiller &…
giuffre-maxwell
gov.uscourts.nysd.447706.1069.0
25 pg
…Maxwell, the
21 procedural history, but when the Second Circuit spoke with
22 regard to this issue, it was very clear that there had been no
23 effective individualized or particularized assessment of any
24 particular discovery item, deposition testimony…
giuffre-maxwell
gov.uscourts.nysd.447706.851.0
158 pg
…next article in the omnibus motion is to
23 exclude testimony references to prior sexual assault. This is
24 an issue that I spoke on yesterday related to another motion
25 regarding the same, so I'll keep it brief.
…
giuffre-maxwell
gov.uscourts.nysd.447706.218.0
25 pg
…2016, counsel for Ms. Churcher spoke by phone to counsel for
Ms. Maxwell and requested an extension of the time to comply with the Subpoena.
Ms. Maxwell’s counsel stated that she would agree to adjourn the date only if…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…before 2015 when the purportedly
defamatory statement was published. Ms. Maxwell testified that she has not spoken to
Mr. Epstein in 2 years.
x Maxwell has not vested any control in Mr. Epstein “in regard to key facts and subject
…
giuffre-maxwell
gov.uscourts.nysd.447706.1100.1
13 pg
…Counsel or Defense Staff are prohibited from further disclosing
or disseminating such identifying information. This Order does
not prohibit Defense Counsel from publicly referencing
individuals who have spoken by name on the public record in this
case.
6. The Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…before 2015 when the purportedly
defamatory statement was published. Ms. Maxwell testified that she has not spoken to
Mr. Epstein in 2 years.
Maxwell has not vested any control in Mr. Epstein “in regard to key facts and subject
…
giuffre-maxwell
gov.uscourts.nysd.447706.1100.0
16 pg
…Counsel or Defense Staff are prohibited from further disclosing
or disseminating such identifying information. This Order does
not prohibit Defense Counsel from publicly referencing
individuals who have spoken by name on the public record in this
case.
6. The Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.23.0
32 pg
…interest. There
5
Case 1:15-cv-07433-RWS Document 23 Filed 12/17/15 Page 11 of 32
is no qualified privilege under New York law when such statements are spoken with malice,
knowledge of their falsity, or…
giuffre-maxwell
1320-28
32 pg
…before 2015 when the purportedly
defamatory statement was published. Ms. Maxwell testified that she has not spoken to
Mr. Epstein in 2 years.
x Maxwell has not vested any control in Mr. Epstein “in regard to key facts and subject
…
giuffre-maxwell
gov.uscourts.nysd.447706.26.1
26 pg
…media for their various roles in recent allegation that defendant hired professional
dissemination of sexual assault allegations made spokespersons to issue defamatory statements
against him was not a non-actionable statement about them to media on his behalf was sufficient
…
giuffre-maxwell
gov.uscourts.nysd.447706.872.0
76 pg
…In addition , as this Court concluded in denying
Maxwell's motion to dismiss , "[t]here is no qualified privilege
under New York law when such statements are spoken with malice ,
knowledge of their falsity , or reckless disregard for their
truth. "…
giuffre-maxwell
gov.uscourts.nysd.447706.25.0
13 pg
…Compl. ¶ 24 (oral statement by Maxwell); Pl.’s Opp’n at 11-12 (contrasting a case
“that sounded in slander (spoken defamation), whereas this is a libel case (written defamation)”); Id. at 24 (“[A]n
action lies in slander for…
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