DataSet-9
EFTA00066510
21 pg
…Maxwell, No.
15-cv-7433 (S.D.N.Y.). alleged that Maxwell defamed her by accusing her of lying
about Maxwell and Jeffrey Epstein sexually abusing her. The law firm Boies Schiller Flexner
LLP (BSF) represented in the dispute. The…
DataSet-9
EFTA00087251
21 pg
…Maxwell, No.
15-cv-7433 (S.D.N.Y.). alleged that Maxwell defamed her by accusing her of lying
about Maxwell and Jeffrey Epstein sexually abusing her. The law firm Boies Schiller Flexner
LLP (BSF) represented in the dispute. The…
DataSet-9
EFTA00106039
21 pg
…for defamation. See No.
(S.D.N.Y.). alleged that Maxwell defamed her by accusing her of lying
about Maxwell and Jeffrey Epstein sexually abusing her. The law firm Boies Schiller Flexner
LLP (BSF) represented in the dispute. The parties…
DataSet-9
EFTA00040664
21 pg
…Maxwell, No.
15-cv-7433 (S.D.N.Y.). =alleged that Maxwell defamed her by accusing her of lying
about Maxwell and Jeffrey Epstein sexually abusing her. The law firm Boies Schiller Flexner
LLP (BSF) represented in the dispute. The…
DataSet-9
EFTA00087230
21 pg
…Maxwell, No.
15-cv-7433 (S.D.N.Y.). alleged that Maxwell defamed her by accusing her of lying
about Maxwell and Jeffrey Epstein sexually abusing her. The law firm Boies Schiller Flexner
LLP (BSF) represented in the dispute. The…
giuffre-maxwell
gov.uscourts.nysd.447706.354.0
40 pg
…the
conferral, Plaintiff’s counsel wrote a letter declining to supplement any of the responses to the
Second Set of Discovery Requests.
PRELIMINARY STATEMENT
Plaintiff has brought a lawsuit alleging Ms. Maxwell defamed her. The defamation
consisted of Ms. Maxwell…
DataSet-9
EFTA00075477
74 pg
…quote, summarize, or characterize both
transcripts.
Statement of the Case and the Facts
The defamation action and the Protective Order.
lleged that Ms. Maxwell defamed her. App. pp 121-24.
The alleged defamation centered on a statement from Ms. Maxwell…
DataSet-9
EFTA01116468
91 pg
…attached as Exhibit G (the
"Maxwell Action"). In her complaint in the Maxwell ActionMalleges that she
was sexually abused and sexually trafficked by Epstein and Maxwell between 1999
and 2002 and that Maxwell defamed her by disputinallegations. See id.
In…
DataSet-9
EFTA00085098
18 pg
…Maxwell in the Over the course of the litigation before
Judge Sweet, three outside parties attempted
Southern District of New York.
to unseal some or all of the sealed material.
alleged that Maxwell had <…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…relevant to
the underlying action. Ransome objects to Defendant being permitted to utilize the underlying
action to obtain backdoor discovery into a separate action entirely unrelated to whether or not
Maxwell defamed Virginia Roberts Giuffre. Ransome further objects to this…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…relevant to
the underlying action. Ransome objects to Defendant being permitted to utilize the underlying
action to obtain backdoor discovery into a separate action entirely unrelated to whether or not
Maxwell defamed Virginia Roberts Giuffre. Ransome further objects to this…
giuffre-maxwell
gov.uscourts.nysd.447706.63.0
22 pg
…Interrog. No. 6) and whether Plaintiff has been defamed by anyone other than
1
Plaintiff additionally asserts that no interrogatories are permitted pursuant to Local Rule 33.3
prior to the last 30 days of discovery. See Menninger Decl. Ex…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…relevant to
the underlying action. Ransome objects to Defendant being permitted to utilize the underlying
action to obtain backdoor discovery into a separate action entirely unrelated to whether or not
Maxwell defamed Virginia Roberts Giuffre. Ransome further objects to this…
giuffre-maxwell
gov.uscourts.nysd.447706.185.8
24 pg
…Action”). In her complaint in the Maxwell Action, Giuffre alleges that she
was sexually abused and sexually trafficked by Epstein and Maxwell between 1999
and 2002 and that Maxwell defamed her by disputing Giuffre’s allegations. See id.
In sum…
DataSet-9
EFTA00508611
19 pg
…also want to release all the provosts
determinations right away. I think we can argue that the one other than Australia defames
my exec assistant so they should not release it. I am working on a redacted version of my
…
DataSet-9
EFTA00068566
2 pg
…photograph of a sign that was hung in the Special Housing Unit that
stated that rounds on Epstein were mandatory, signed "God," which had been defaced to include a
question mark after "mandatory"; (iii) Epstein's psychological records at MCC…
DataSet-9
EFTA00040626
2 pg
…photograph of a sign that was
hung in the Special Housing Unit that stated that rounds on Epstein were mandatory, signed "God," which had been
defaced to include a question mark after "mandatory"; (iii) Epstein's psychological records at MCC…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.1_1
13 pg
…unconscious, it is rape.
Accordingly, this Court should put a stop to Defendant’s plan to defame Ms. Giuffre again
by telling the public that she “cried rape” through the Defendant’s public release of these police
reports depicting Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…16 Filed 01/27/21 Page 6 of 12
Case 1:15-cv-07433-LAP Document 1199-16 Filed 01/27/21 Page 7 of 12
her close relationship with Jeffrey Epstein and plotted with him to defame Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…too, can take
confidential litigation materials to the press.3 As the adverse testimonial evidence piles up
against Defendant,4 it appears she and Dershowitz are planning another media blitz in an attempt
to discredit and defame Ms. Giuffre.
The…