giuffre-maxwell
gov.uscourts.nysd.447706.1090.28_4
5 pg
…party in any criminal action pertaining to JE
Every story in the press innuendo and comment has been taken from civ
depositions against JE, which were settled many years ago. None of the
depositions were ever subject to cross examination…
giuffre-maxwell
gov.uscourts.nysd.447706.541.0
10 pg
…produce
clear and convincing evidence of its falsity. ........................................................... 56
1. The January 2015 statement accurately denied that Ms. Maxwell met
Plaintiff when Plaintiff was 15 years old in 1999. ..................…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.3_1
2 pg
…likely because there is none. GM 748-840 are various
police reports that have been publicly available for years. GM 841-849 are
public comments about your client's story which are available to the world by
a simple Google…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.16
2 pg
…Intervenor Dershowitz
supports the pending application. As this Court knows, Intervenor Dershowitz has been
litigating to unseal materials from this case for nearly two years. Indeed, at this very moment,
Intervenor’s appeal of this Court’s order denying his…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.14
3 pg
…edition and on web
vvww.dailymail.co.uk/news/article-2965360/Prince-Andrew-s-sex-slave-accused-two-tcens-rape-three-years-
joincd-Jeffrey-Epstein-s-harem.html
and
www.nydailynews.com/ news/worJd/sex-slave-prince-andrew-accused-2…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.2
3 pg
…her 'not credible'
Ghislaine
Some helpful leakage ...
In today's Daily Mail print edition and on web
www.dailymail .eo.uk/news/article-2965360/Prince-Andrew-s-sex-slave-accused-two-tcells-rape-three-years-
joined-Jeffrey-Epstein-s-harem…
giuffre-maxwell
1320-14
3 pg
…edition and on web
vvww.dailymail.co.uk/news/article-2965360/Prince-Andrew-s-sex-slave-accused-two-tcens-rape-three-years-
joincd-Jeffrey-Epstein-s-harem.html
and
www.nydailynews.com/ news/worJd/sex-slave-prince-andrew-accused-2…
giuffre-maxwell
gov.uscourts.nysd.447706.26.1
26 pg
…which state’s law applies by applying forum
statement gave rise to new defamation claim; state’s choice of law rules.
[2]
celebrity’s statement that alleged victim’s accusation
that he had sexually assaulted her was “10-year-old, …
giuffre-maxwell
gov.uscourts.nysd.447706.22.0
14 pg
…Plaintiff clearly seeks to litigate her false and
malicious accusations of sexual abuse against Ms. Maxwell. For years, Ms. Maxwell has
suffered Plaintiff’s unabated and unfiltered character attacks in both the media and in thinly-
veiled press releases masquerading…
giuffre-maxwell
gov.uscourts.nysd.447706.610.0
3 pg
…1982)). The parties cannot possibly establish such reasons
with respect to the summary judgment record in this case, as the substance of Plaintiff’s
allegations have been a matter of public record for years. See ECF No. 364 at 4…
giuffre-maxwell
gov.uscourts.nysd.447706.538.0
10 pg
…produce
clear and convincing evidence of its falsity. ........................................................... 56
1. The January 2015 statement accurately denied that Ms. Maxwell met
Plaintiff when Plaintiff was 15 years old in 1999. ..................…
giuffre-maxwell
gov.uscourts.nysd.447706.931.0
15 pg
…THE COURT: What an unusual circumstance.
2 MR. MILLER: But, the e-mails tell the story of what
3 happened 10 years ago. The e-mails talk about her
4 contemporaneous views of those things. They attach the
5 photographs…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…Jeffrey
bought her. She’d always wanted to fly and Jeffrey paid for her to take lessons,
and I remember she was very excited because she got her license around the first
year we met. I used to get frightened…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…the Virgin Islands and then helicoptered to Little St. James.
Id., ¶ 46. Air traffic controller reports state that some victims appeared to be as young as 11
years old. Id., ¶ 51. Evidence also shows that when two of the victims…
giuffre-maxwell
gov.uscourts.nysd.447706.1302.0
3 pg
…2016, six years
before TGP moved to intervene. 3 We find no abuse of discretion in the District Court’s conclusion
that permitting TGP to intervene at this late stage “would unduly delay the adjudication of the rights
of the…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.13
22 pg
…such orders will be inhibited from giving essential
testimony in civil litigation, thus undermining a procedural system that has been
successfully developed over the years for disposition of civil differences. In short,
witnesses might be expected frequently to refuse to…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.30
16 pg
…3. This argument is fundamentally flawed for
five reasons.
First, the very news articles cited by Plaintiff document that the townhome had been on
the market for sale for over a year - i.e., since at least April of 2015…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…As you may recall, Edwards and Cassell sued Dershowitz for defamation last year
in Florida state court. The two lawyers alleged that Dershowitz defamed them when he claimed
that they knowingly filed a lawsuit containing falsehoods about him or at…
giuffre-maxwell
gov.uscourts.nysd.447706.1312.0
9 pg
…their names are already in the public record, and have been for several years.”). “It’s not the
job of the Court to police press coverage and alert the public when reporting on unsealed materials
concerning intimate matters where the…
giuffre-maxwell
gov.uscourts.nysd.447706.1105.0
8 pg
…first place. The Court
accordingly concludes that such reliance on the Maxwell Protective
Order precludes modification.
Id. This remains true and, here, is outcome-determinative.
Years ago, in a different case, involving different parties, represented by different
lawyers, non-parties…
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