DataSet-9
EFTA01182998
70 pg
…information requested above is in the possession of Defendant who has failed to comply with
her production obligations in this matter.
7. State whether You believe that You have ever been defamed by anyone other than
Ghislaine Maxwell. If so…
DataSet-9
EFTA00584062
22 pg
…Cassell then filed this action, alleging that Dershowitz defamed them by
"initiat[ing] a massive public media assault on the reputation and character of [Edwards] and
[Cassell] accusing them of intentionally lying in their filing, of having leveled knowingly false…
DataSet-9
EFTA00595583
29 pg
…known that the statements were false is insufficient. /d.9 To
establish malice, a defamed plaintiff must show...that such malicious motivation was the one
and only cause for the publication." Hoesten v. Best, 821 N.Y.S.2d 40 …
DataSet-9
EFTA00277107
6 pg
…my
belongings, my evidence of crimes against me by Howard Dinin with others. Immediately following the theft on
the 8th Vita Smith (Howard Dinin's sister) screamed at me, defamed me, attacked my character, called me a
"phony", called me…
DataSet-9
EFTA01099134
26 pg
…2015.
On January 6, 2015, Edwards and Cassell filed this action, alleging that Dershowitz had
defamed them by attacking their honesty and integrity in the course of their representation of
their client. On February 10, 2015, Dershowitz filed an answer…
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.447706.35.0
31 pg
…the complaint). The blatant nature of the defendant’s failure to participate in
discovery is akin to the conduct for which the Second Circuit has awarded sanctions.
This case turns on whether or not Maxwell defamed Ms. Giuffre when she…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
…5 have not heard that term used, I think what she may be
6 referring to was the fact that this is a defamation claim and
7 the person who defamed my client was also an abuser, we allege.
8…
giuffre-maxwell
gov.uscourts.nysd.447706.363.6
15 pg
…Jane Doe No. 3. None of that childhood abuse is relevant to this case
which involves the narrow issue of whether Defendant defamed two lawyers. Defendant’s
subpoena is both unreasonable and oppressive and should be quashed. See Matthews v…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…information requested above is
in the possession of Defendant who has failed to comply with her production obligations in
this matter.
7. State whether You believe that You have ever been defamed by anyone other than
Ghislaine Maxwell. If so…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…collateral” attack on Plaintiff’s credibility,
but much more importantly, to disprove Giuffre’s claims that Dershowitz defamed her by calling
her a “serial liar” and stating that she has a “documented history of lying about prominent people.”
Am. Compl.…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…Ms.
Giuffre, Dershowitz called those girls liars and defamed them as prostitutes,14 in an effort to
convince the State Attorney that these girls could not even believably establish that they had ever
even gone to Epstein’s mansion. Later…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.11
15 pg
…job was for Epstein.7
That other young females were similarly recruited by the Defendant is evidence that Ms.
Giuffre is telling the truth about her experiences – and thus direct evidence that Defendant
defamed her when calling her a liar…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.2
23 pg
…Maxwell, a civil defamation case Virginia
Giuffre filed in 2015. Giuffre claimed that Maxwell defamed her when Maxwell’s attorney-hired
press agent denied as “untrue” and “obvious lies” Giuffre’s numerous allegations, over the span
of four years, that…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…5 Filed 01/05/24 Page 10 of 45
This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
7. State whether You believe that You have ever been defamed by anyone other than
Ghislaine Maxwell. If so…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…information requested above is in the possession of Defendant who has failed to comply with
her production obligations in this matter.
7. State whether You believe that You have ever been defamed by anyone other than
Ghislaine Maxwell. If so…
giuffre-maxwell
gov.uscourts.nysd.447706.1071.0
13 pg
…was underage. Ms. Giuffre
alleges that Mr. Dershowitz’s false denial of such contact defamed
her. To be sure, the two actions are related because they involve
the alleged behavior of individuals who were in Epstein’s
substantial orbit, but…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.4_1
29 pg
…Dershowitz”) for defamation in Florida state court. The subject matter of that
litigation concerned whether Mr. Dershowitz defamed Plaintiff’s attorneys by claiming
a) Plaintiff is lying; b) Edwards and Cassell knew Plaintiff is lying; c) Edwards and Cassell helped…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.24
16 pg
…job was for Epstein.8
That other young females were similarly recruited by the Defendant is evidence that Ms.
Giuffre is telling the truth about her experiences – and thus direct evidence that Defendant
defamed her when calling her a liar…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…information requested above is in the possession of Defendant who has failed to comply with
her production obligations in this matter.
7. State whether You believe that You have ever been defamed by anyone other than
Ghislaine Maxwell. If so…