gov.uscourts.nysd.447706.30.0.pdf

Case 1:15-cv-07433-RWS Document 30 Filed 01/25/16 Page 1 of 3 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 RESPONSE TO DEFENDANT’S NOTICE OF SUPPLEMENTAL AUTHORITY In response to Defendant’s Notice of Supplemental Authority [D.E. # 29], Plaintiff Virginia L. Giuffre, by and through her undersigned counsel, respectfully states as follows: As recounted by Defendant’s Notice of Supplemental Authority, the Hill Court found that Cosby’s statements were not defamatory because they did not “lead to an inference that Plaintiff is a ‘liar and an extortionist.’” In vivid contrast, Maxwell called Ms. Giuffre’s assertions of sexual abuse “obvious lies.” It is axiomatic that a person telling “obvious lies” is a liar, and, therefore, the reasoning employed by the Hill court is inapplicable to the statements made by Maxwell. Dated January 25, 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 1 Case 1:15-cv-07433-RWS Document 30 Filed 01/25/16 Page 2 of 3 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  Case 1:15-cv-07433-RWS Document 30 Filed 01/25/16 Page 3 of 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on January 25, 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