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Extracted Text (OCR)
Case 1:15-cv-07433-LAP Document 1332-5 Filed 01/08/24 Page 6 of 9
press to stop and think before publishing, to cease and desist, and that if they continued then they
faced higher damages for ignoring my clear warning.
19. Consistent with those two purposes, Mr. Gow’s emails prefaced the statement with
the following language: “Please find attached a quotable statement on behalf of Ms Maxwell”
(italics supplied). The statement was intended to be a single, one-time-only, comprehensive
response—quoted in full, if it was to be used—to plaintiff's December 30, 2014, allegations that
would give the media Ms. Maxwell’s response. The purpose of the prefatory statement was to
inform the media-recipients of this intent.
20. Selective and partial quotation and use of the statement would disserve my purposes.
It was intended to address Plaintiff's behavior and allegations against Ms. Maxwell on a broad
scale, that is to say, Plaintiff's history of making false allegations and innuendo to the media
against Ms. Maxwell. This is why the statement references Plaintiffs “original allegations” and
points out that her story “changes”—i.e. is embellished—over time including the allegations
“now” that Professor Dershowitz allegedly had sexual relations with her. This is why I
distinguished in the statement between Plaintiff's “original” allegations and her “new,” joinder-
motion allegations, which differed substantially from the original allegations. And this is why I
wrote, “Each time the story is re told [sic] it changes with new salacious details about public
figures and world leaders and now it is alleged by [Plaintiff] that Alan Derschowitz [sic] is
involved in having sexual relations with her, which he denies.” (Emphasis supplied.) Having
established the dramatic difference between Plaintiffs two sets of allegations, which suggested
she was fabricating more and more-salacious allegations as she had more time to manufacture
them, I added the third paragraph: “[Ms. Giuffre’s] claims are obvious lies and should be treated
as such and not publicised as news, as they are defamatory.” (Emphasis supplied.) I believed
then, and believe now, that it was and remains a fair inference and conclusion that her claims
Extracted Information
Dates
Document Details
| Filename | Giuffre_Maxwell_Batch7_p00115.png |
| File Size | 309.1 KB |
| OCR Confidence | 94.6% |
| Has Readable Text | Yes |
| Text Length | 2,231 characters |
| Indexed | 2026-02-04 12:47:42.608485 |