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é Case 18-2868, Document 287, 08/09/2019, 2628251, Page52 of 76 abuse. Giuffre attempts to promote Victims Refuse Silence at every opportunity. For example, Giuffre participated in an interview in New York with ABC to promote the charity and to get her mission out to the public. Giuffre has denied that she formed the non-profit Victims Refuse Silence to “speak out on a public controversy,” and noted she sought to help survivors of sexual abuse and sexual trafficking and in order to provide assistance to victims, she attempted to talk about the non-profit’s mission when she had the opportunity to do so. IIt. The Applicable Standard Summary judgment is appropriate only where “there is no genuine issue as to any material fact and... the moving party is entitled to a judgment as a matter of law.” Fed. R. Civ. P. 56(c). “[T]he substantive law will identify which facts are material.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). A dispute is “genuine” if “the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” 52

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Filename DocumentCloud_Epstein_Docs_p02000.png
File Size 325.7 KB
OCR Confidence 94.7%
Has Readable Text Yes
Text Length 1,082 characters
Indexed 2026-02-04 12:31:46.502983