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Case 1:15-cv-07433-LAP Document 1332-10 Filed 01/08/24 Page 33 of 64 32
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not true, to say that any of them were false.
Judge, I don't know that this is an adventure that is
going to get us very far. The Court is setting a one-month
trial for us to figure out whether these hundreds of
allegations made by the plaintiff are true or false, but what
was trying to do, Judge, was cut to the chase. Are there at
least two allegations, plural? Because the Second Circuit in
the Law Firm of Foster Case says that substantial accuracy is
the standard here for defendants, not literal accuracy. But
what I am trying to focus on is that, if that's the standard,
Judge, and we show you literal accuracy, then surely we win on
the Law Firm of Foster Case.
Judge, may I approach the Court? I have a hand-out I
would like to share with the Court.
So that I don't need to discuss this on the record,
Judge, I ask two things. Number one, that the Court let me
know when it has finished reading this, and, number two, I
would like for this document to be included in today's record.
THE COURT: ecr
MR. GEE: Thank you, Judge.
What I have done here is to do a very simple
comparison between the March 2011 allegations, i.e., the
original allegations by the plaintiff, and her new, her CVRA
joinder motion allegations. The first allegations were given
to Sharon Churcher, reporter, for $160,000, where Ms. Churcher
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Document Details
| Filename | Giuffre_Maxwell_Batch7_p00230.png |
| File Size | 267.6 KB |
| OCR Confidence | 94.9% |
| Has Readable Text | Yes |
| Text Length | 1,484 characters |
| Indexed | 2026-02-04 12:48:12.577184 |