323 results for "January 2 2015"
Page 1 of 13
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Case 18-2868, Document 278, 08/09/2019, 2628230, Page49 of 648
ROSS NEIL SUTHERLAND GOW - 11/18/2016 Page 4
1 EXHIBIT INDEX
2 No. Description Page
3 4 Email from Ross Gow to G Max, 35
4 cc Brian Basham, dated January 2, 2015,
5 Bates No. GM...
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...The January 2015 statement was substantially true, and plaintiff cannot produce
clear and convincing evidence of its falsity... ccc eeseeeseeseeseeeeneeaeeseeeeseeeeneeeeaees 56
1. The January 2015 statement accurately denied that Ms. Maxwell met
Plaintiff when Plaintiff was 15 years old in 1999... eeeseeseeseeeeteeeees 56
2. The January 2015 statement accurately denied...
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...ceceeseeseeseeeeteeseeeeeeeseeeenteneeeees 2
A. Summary judgment is warranted to the extent plaintiff seeks to impose liability on
any media’s republication of all or a portion of the January 2015 statement. ........ 2
B. Because plaintiff is a limited public figure, imposing liability upon Ms. Maxwell
for republication of the January 2015...
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...The document states, it's Saturday
January 3, 2015. You issued your press
release on January 2, 2015.
Were you discussing with Prince
Andrew the subject of Virginia Roberts during
these calls?
MR. PAGLIUCA: Objection to the
form and foundation.
A. I don't know if I spoke to him...
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...huffingtonpost.co.uk/2015/01/03/duk
e-of-york-sex-abuse-claims_n_6409508.html
January 4, 2015
Internet
Jewish News
Online
http://www.jewishnews.co.uk/dershowitz-nothing-
prince-andrews-sex-scandal/
January 2, 2015
Internet
Bolton News
http://www.theboltonnews.co.uk/news/na
tional/11700192.Palace...
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...Friday, January 9, 2015 2:18 PM
Subject: Re: we'll see
Normally it's the copilots job to call out JJ, in this instance I'm calling her out)):
On Friday, January 9, 2015, iS wrote:
| know, | like where it's going..
From: jeffrey E.
To...
HOUSE_OVERSIGHT_021818.jpg
...Friday, January 9, 2015 2:18 PM
Subject: Re: we'll see
Normally it's the copilots job to call out J, in this instance I'm calling her out)):
On Friday, January 9, 2015 i yrote:
| know, | like where it's going..
From: jeffrey E.
To...
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...January 2.2015 | Intemet Bolton News ‘tip: www. theboltonnews co.uk‘news'national/11700192
“Palace denies Andrew sex case claim/
January 3,2015 | Internet Telegraph ‘ihttp://www.telegraph.co.uk/news/uknews’theroyalfamily/
11323872/Prince-Andrew-denies-having-relations-with-
sex-slave-girl htm!
January 3,2015 | Internet Daily Mail...
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...So is it correct without telling me what you talked to your lawyers about that
you knew because this is dated January 10 that when you made this statement
in early January, January 2 of 2015 you knew that calling Virginia a liar
would subject you to a legal action...
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...cece ecseseescsesecscsesscscsesecscsesecscsesssscsesessssesesecsesesessesssecsesssessesesesseseeeeased 2
I. Ms. Maxwell is not liable for republications of the January 2015 statement. .............. 2
A. Plaintiff's argument against summary judgment is substantially groundless. 2
B. New York state and federal courts have rejected liability for republication
based on “foreseeability.” oe eceesceesececeneeeesessescseseeessessesssesesseseseeeeaeee 5
C. Plaintiff's purported...
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...Giuffre have been disseminated to at least
115 online media or other sites in 178 separate stories or articles with a combined
66,909,965 individual unique visitors from 2 January 2015 to the date that I filed this
report, inclusive. More likely than not, this is a conservative estimate...
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...Giuffre appear on 2 January 2015
i
Ms. Maxwell confirms the statements made against Ms.
Giuffre in a New Daily News video on 5 January 2015
i
I Continued news coverage with articles referencingthe
I statements made against Ms. Giuffre appearing ina
| variety of news outlets from February through April...
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Case 18-2868, Document 278, 08/09/2019, 2628230, Page50 of 648
ROSS NEIL SUTHERLAND GOW - 11/18/2016 Page 5
1 EXHIBIT INDEX
2 No. Description Page
3 10 Email from gmaxl@ellmax.com, sent: 50
4 Saturday January 10, 2015,
5 To Philip Barden; Ross Gow,
6 Bates...
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Case 18-2868, Document 278, 08/09/2019, 2628230, Page51 of 648
ROSS NEIL SUTHERLAND GOW - 11/18/2016 Page 6
1 EXHIBIT INDEX
2 No. Description Page
3 14 Email chain, latest in time from 68
4 Nick Sommerlad, dated 2 January 2015,
5 21:45, To ross@acuityreputation...
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...Friday, January 2, 2015 at 14:01 PM
To: gmax
Subject: Agreed copy
G
Sorry about that, was going through Eurotunnel passport control.
Still haven't received your mail...
Best
Ross
Sent from my BlackBerry® wireless device
From:
Date: Fri, 2 Jan 2015 17:06:35 +0000
To: G Max...
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...Friday, January 9, 2015 7:27 PM
To: jeffrey E.
Subject: Re: we'll see
Importance: High
I'm a pilot...| prefer sex slave to copilot ;)
From: jeffrey E.
To: Nadia
Sent: Friday, January 9, 2015 2:18 PM
Subject: Re: we'll see...
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...6, in
connection with the media’s publication of portions of the January 2015 statement. EXHIBIT J
4] 24; EXHIBIT K ff 2-3..
35. Plaintiff's defamation action against Ms. Maxwell. Eight years after Epstein’s
guilty plea, plaintiff brought this action, repeating many of the allegations she made...
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...Giuffre is shown in Figure 2.
34. Figure 2: Timeline of events relating to the dissemination of the statements
made against Ms. Giuffre from 2 January 2015 onwards.
B https://www.thesun.co.uk/archives/news/6754/prince-andrews-pal-ghislaine-groped-teen-girls/
' http://www.mirror.co.uk/news...
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...1/10/2015 2:36:20 PM
To: G Maxwell [GMax1@ellmax.com]
Subject: Re:
ok
On Sat, Jan 10, 2015 at 10:33 AM, G Maxwell wrote:
| need it written out in full.
THE TERRAMAR PROJECT
FACEBOOK
TWITTER
G+
PINTEREST
INSTAGRAM
PLEDGE
THE DAILY CATCH
From...
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...1/10/2015 2:41:47 PM
To: G Maxwell [GMax1@ellmax.com]
Subject: Re:
call me
On Sat, Jan 10, 2015 at 10:33 AM, G Maxwell wrote:
| need it written out in full.
THE TERRAMAR PROJECT
FACEBOOK
TWITTER
G+
PINTEREST
INSTAGRAM
PLEDGE
THE DAILY CATCH...
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...2. [have no control or authority over amy media organizations, including those media
organizations that published any part of a January 2015 statement issued on mv behalf at the
direction of my aliomey, Philip Barden.
3. Neither | nor any agent acting on my behalf approved or participated in any activity...
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...The initial statement is January,
and when
is this?
MS. SCHULTZ: So, your Honor, the email that went to
the media, it was first issued on January 2, 2015; it was
published on January 3, 2015; and the statement took place the
next day, on January 4, 2015.
THE
COURT...
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...Notable conventions scheduled
in Las Vegas during 2015 and 2016 include the following:
CONVENTIONS & TRADE SHOWS (2015-2016)
DATE
January-16
November-15
January-16
August-16
February-16
September-15
September-15
March-16
May-16
June-16
May-16
April-16
March-16
October-15
September-15
June...
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...Was the press release that you
issued with the statement about Virginia
issued in or around January 2, 2015?
A. As best as I can recollect.
Q. I want to turn your attention to
the document I just handed you which is Bates
No. 001044, from you to Philip Barden...
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...Was the press release that you
issued with the statement about Virginia
issued in or around January 2, 2015?
A. As best as I can recollect.
Q. I want to turn your attention to
the document I just handed you which is Bates
No. 001044, from you to Philip Barden...
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