gov.uscourts.nysd.447706.26.0.pdf

United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAIINTIFF, VIRGINIA L. GIUFFRE’S NOTICE OF SUPPLEMENTAL AUTHORITY In further support of her Opposition to Defendant’s Motion to Dismiss the Complaint, Plaintiff Virginia L. Giuffre, by and through her undersigned counsel, respectfully submits the recent decision in Green v. Cosby, 3:14-cv-30211-MGM, 2015 WL 5923553 (D. Mass., Oct. 15, 2015) (“Cosby”) (attached as Exhibit A). In Cosby, the court denied Bill Cosby’s motion to dismiss the sexual assault victim’s defamation complaint, holding that Cosby’s “suggestion that Plaintiff intentionally lied about being sexually assaulted” could expose plaintiff to “‘scorn or ridicule,” and, therefore, Cosby’s statement could be found to have a “defamatory meaning.” Green v. Cosby, No. CV 14-30211- MGM, 2015 WL 5923553, at *11 (D. Mass. Oct. 9, 2015). The Cosby decision is relevant to arguments advanced by Defendant in support of her motion to dismiss, and therefore, Plaintiff respectfully requests that the Court take notice of this supplemental authority. 1 Dated January 8, 2015 Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boies Boies Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Ellen Brockman Boies Schiller & Flexner LLP 575 Lexington Ave New York, New York 10022 (212) 446-2300 2  CERTIFICATE OF SERVICE I HEREBY CERTIFY that on January 8, 2016, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. Laura A. Menninger, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: [email protected] /s/ Sigrid S. McCawley Sigrid S. McCawley 3