Giuffre_Maxwell_Batch2_p00297.png

LO Li LZ 13 14 is 16 LY 18 LS 20 21 22 23 24 25 Case 1:15-cv-07433-LAP Document 1325-18 Filed 01/04/24 Page 12 of 23 Pr G1ETGIUA and set forth their allegations against him. One of his colleagues came forth and called those victims liars publicly, same thing that happened in this case. And the court there said that the case cannot be dismissed, it has to proceed forward, and they are entitled to prove those allegations were false, that the victims were not liars, and indeed they were subject to the abuse they were subject to. Another case that is recent which I supplemented with your Honor is the Cosby case. It's recent out of Massachusetts, and very similarly there -- in fact, the statements weren't even as strong as Ms. Maxwell's statements here. In our complaint, Ms. Maxwell calls our client's allegations of sexual abuse, quote, obvious lies, issued by press release nationally and internationally to the media. And we do cite to the media that it is sent to. That's in paragraph 30, 36 and 37, international media, national media and the New York Daily Post, who interviewed Ms. Maxwell on a New York street. So that is alleged in detail in our complaint. But in Cosby the court said, quote, suggestions that a plaintiff intentionally lied about being sexually assaulted could expose that plaintiff to scorn and ridicule, and therefore, Bill Cosby's statements could be found to have a defamatory meaning, and the court allowed the case to proceed past the motion to dismiss stage. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300