giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…144, 147, 171 AND 183’S OBJECTIONS TO UNSEALING
Case 1:15-cv-07433-LAP Document 1247 Filed 03/18/22 Page 2 of 25
TABLE OF CONTENTS
PRELIMINARY STATEMENT .................................................................................................1
ARGUMENT .........…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.1
8 pg
…behalf of our client, Ghislaine Maxwell, we write to request that the Court enter an
order prohibiting the Government, its agents and counsel for witnesses from making extrajudicial
statements concerning this case. Although Ms. Maxwell is presumed innocent, the Government,…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…Ghislaine Maxwell, by and through her undersigned counsel, hereby responds
to Plaintiff’s First Set of Interrogatories (the “Interrogatories”).
PRELIMINARY STATEMENT AND GENERAL OBJECTIONS
1. This response is made to the best of Ms. Maxwell’s present knowledge,
information and…
giuffre-maxwell
gov.uscourts.nysd.447706.562.1
13 pg
…Maxwell”), avers
upon personal knowledge as to her own acts and status and otherwise upon information and
belief:
NATURE OF THE ACTION
1. This suit arises out of Defendant Maxwell’s defamatory statements against
Plaintiff Giuffre. As described below, Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.363.13
15 pg
…[email protected]
Attorneys for Non-Party Sharon Churcher
Case
Case1:15-cv-07433-LAP
1:15-cv-07433-RWSDocument
Document363-13 Filed07/05/16
263 Filed 08/11/16 Page
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…York and transferring the money outside the jurisdiction.
Accordingly, Defendant’s motion for a protective order should be denied.1
I. PRELIMINARY STATEMENT
As recounted by Defendant (DE 370 at 1-3), Ms. Giuffre has served discovery requests
on Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.1.0
12 pg
…Maxwell”), avers
upon personal knowledge as to her own acts and status and otherwise upon information and
belief:
NATURE OF THE ACTION
1. This suit arises out of Defendant Maxwell’s defamatory statements against
Plaintiff Giuffre. As described below, Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.263.0
14 pg
…8230
Facsimile: (212) 489-8340
[email protected]
[email protected]
Attorneys for Non-Party Sharon Churcher
Case 1:15-cv-07433-RWS Document 263 Filed 07/05/16 Page 2 of 14
…
giuffre-maxwell
gov.uscourts.nysd.447706.24.1
13 pg
…Maxwell”), avers
upon personal knowledge as to her own acts and status and otherwise upon information and
belief:
NATURE OF THE ACTION
1. This suit arises out of Defendant Maxwell’s defamatory statements against
Plaintiff Giuffre. As described below, Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.561.0
22 pg
…Lauderdale, FL 33301
(954) 356-0011
Case 1:15-cv-07433-LAP Document 561 Filed 01/27/17 Page 2 of 22
TABLE OF CONTENTS
…
giuffre-maxwell
gov.uscourts.nysd.447706.235.2
4 pg
…May 3rd,
please provide the following documents on or before April 27th, 2016.
All documents withheld on the basis of the “public interest privilege,” other
than Plaintiff’s actual statements to any law enforcement agency, which are to
be…
giuffre-maxwell
gov.uscourts.nysd.447706.57.1
26 pg
…was that on the day of the
accident a brief report was made to the railway inspectorate,
soon afterwards a joint internal report (" the joint inquiry
report") was prepared incorporating statements of witnesses,
which was also sent to the inspectorate…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…Schiller & Flexner, which also represents Virginia Giuffre, issued this
statement earlier today: “Virginia Giuffre was not a party to that [defamation] lawsuit and was
not a party to the settlement. We continue to represent Ms. Giuffre in other litigation and…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.43
4 pg
…but two statements saying Prince
Andrew is completely innocent of all the accusations.
VICTORIA MURPHY: They issued one statement initially in response to the allegations
that Prince Andrew had had sex with an underage minor and that was what they…
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
…by the defendant with a certain
12 level of culpability and resulting injury. Depending on the
13 context of the words, the content of the statement, the
14 relationship of the speaker and the listener, depending on the
15 time…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.46
14 pg
…concerning Plaintiff’s medical and mental health treatment, (b) her unjustifiable refusal
to answer questions related to statements the media “got wrong,” (c) material edits to her
deposition testimony through her errata sheet. Plaintiff did not address her newly disclosed…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…the three that we had alternative service for, and then we have
12 Mr. Ross GOw, who was the defendant's agent who issued the
13 defamatory statement, Mr. Brunel --
14 THE COURT: How much time do you want?
15 …
giuffre-maxwell
gov.uscourts.nysd.447706.1201.17
12 pg
…Ms.
Giuffre’s motion should be granted.
I. PRELIMINARY STATEMENT
Defendant begins her brief with snippets of her self-serving testimony. As the Court is aware,
all of this testimony is directly contradicted by the myriad of other witnesses in…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.35
10 pg
…irrelevant to
this lawsuit whether Ms. Maxwell engaged in consensual, adult sexual activities with women.
There is no allegedly defamatory statement that has anything to do with Ms. Maxwell’s private
adult sex life. It is an abuse of this…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.40
19 pg
…Ms. Maxwell is the Defendant and may have knowledge concerning matters at
issue, including the events of 1999-2002 and the publication of statements in the
press in 2011-2015.
2. Virginia Lee Roberts Giuffre
c/o Sigrid S. McCawley…
Comments