321 results for "January 24 2015"
Page 11 of 13
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...Did you ever delete emails in
January of 2015?
A. Ihave not deleted anything that
you have asked me for in discovery. I have
given you everything that I have.
Q. That is not my question, my
question is, did you ever delete emails in
January of 2015?
A. Inthe...
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...I
challenge you to find any statement where I said I have
never traveled outside the presence of my wife, close
quote, representing that there would be no such
statement there, when, in fact, I'm aware of an American
Lawyer quotation attributed to him from January 15th,
2015, quote...
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...In January 2015, Ms. Giuffre’s
attorneys, Mr. Edwards and Mr. Cassell, sued Professor Dershowitz for defamation, citing
comments he made in his own defense. /d. § 21. During discovery in that action, Ms. Giuffre
never produced the Emails or the Manuscript despite a court order requiring her to provide all...
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...Gow to issue the January 2015 statement. Mot. 3. We suggest plaintiff's persistent repetition
of her arguments—as with any repetition, they have become familiar, but not more persuasive—
suggests her recognition that we have advanced meritorious and weighty arguments for summary
‘Mot. 3 (emphasis supplied).
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...Barden’s “intent” in allegedly being the main drafter of Defendant’s January 2,
2015 press release. (DE 586 at p. 34) In Reply, Defendant conceded that in submitting Barden’s
declaration, she had waived the work-product privilege, but denied a waiver of the attorney-
client privilege. (DE 620...
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Case 18-2868, Document 280, 08/09/2019, 2628232, Page65 of 74
Defendant, by way of her January 2015 statement, declared that Ms. Giuffre lied about
each and every one of these allegations regarding Defendant. In fact, Defendant clarified further
this position in her deposition when she said repeatedly that...
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...at Exhibit 2, January 8, 2015, The Sun (online) article: “Prince
99
Andrew’s pal Ghislaine ‘groped teen girls,”” (Miss Maxwell’s spokesman branded the
accusations against her a “web of lies and deceit” — adding: “None of these allegations are on
oath. “These girls are saying anything they want for...
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Case 1:15-cv-07433-LAP Document 1320-1 Filed 01/03/24 Page 2 of 2
From: gmax1@ellmax.com
Sent: Saturday, January 10, 2015 9:00 AM
Ta: Philip Barden; Ross Gow
tam out of my depth to understanding defamation and other legal hazards and don’t want...
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Case 1:15-cv-07433-LAP Document 1330-21 Filed 01/05/24 Page 2 of 11
From: gmax1@ellmax.com
Sent: Saturday, January 10, 2015 9:00 AM
To: Philip Barden; Ross Gow
!am out of my depth to understanding defamation and other legal hazards and don't want...
Giuffre_Maxwell_Batch6_p00378.png
...the Sex Offender Who Mixes
with Princes and Premiers,” January 29, 2015, available at
http://www.newsweek.com/2015/02/06/sex-offender-who-mixes-princes-and-premiers-302877.html
(last visited February 17, 2017). He is the subject of a recently released book by best-selling author
James Patterson...
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Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 16 of 27
there. It was not, as Mr. Cassell misleadingly suggests, an affirmation that Ms. Giuffre and I
were present at Mr. Epstein’s house at the same time.
37. In fact, Mr. Alessi has...
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...Gow and my client, on January 2, 2015, I prepared a further
statement denying the allegations, and I instructed Mr. Gow to transmit it via email to members
of the British media who had made inquiry about plaintiffs allegations about Ms. Maxwell.
Schultz Decl., Exh. 2, Barden Declaration, at 2...
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...Barden discusses his intent and purpose
in preparing the January 2015 statement. We quote in full the two sentences so that the Court can
see for itself the remarkably frivolous nature of the argument: “I did not ask Ms. Maxwell to
respond point by point to Ms. Giuffre’s factual...
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...Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 20 of 26
3. The video(s) of Ghislaine Maxwell adopting the January, 2015 press statement.
4. All newspaper or other media where Ghislaine Maxwell’s press release appears
5. All evidence obtained by the Federal...
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...Maxwell is not liable for republications of the January 2015 statement.
Under black letter New York law, liability for republication of an allegedly defamatory
statement “must be based on real authority to influence the final product.” Davis v. Costa-
Gavras, 580 F. Supp. 1082, 1096 (S.D.N.Y. 1984...
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...1.3K
Emails, letters, and _|retained by attorneys to |Legal Assistants, work product related to the Dershowitz case, and/or Work docs
other communications |aid in the rendition of __ |Professionals retained by lcommunications sending or attaching client revisions to Product/joint overlapping
from January 2015 - legal advice and attorneys to...
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...1.3K
Emails, letters, and _|retained by attorneys to |Legal Assistants, ]work product related to the Dershowitz case, and/or Work docs
other communications aid in the rendition of _ | Professionals retained by lcommunications sending or attaching client revisions to Product/joint overlapping
from January 2015 - |legal advice and attorneys to...
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...33
Produce all corporate securities (stocks or bonds), foreign or domestic, directly or
indirectly held by You, or held on Your behalf or for Your benefit by another individual or
entity, including trusts from January 2015 to the Present.
RESPONSE: Ms. Maxwell objects to this Request on the grounds that...
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...Giuffre in January 2015 and thereafter that remain in the
public realm. Ms. Giuffre does not have knowledge as to every time and place
that she was defamed by Dershowitz, and she is not required to provide such an
exhaustive list as all relevant instances of defamation are available through...
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...22 Maxwell?
23 Q_ And what was -- who was this boss that you | 23 A In 2015?
24 spoke to? 24 Q Um-hum.
25 A Ican't remember his name. 25 A __ Did I talk to any law enforcement about
Page 242 Page 244
1 Q_ Okay. 1 Ghislaine...
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Case 1:15-cv-07433-LAP Document 1325-1 Filed 01/04/24 Page 7 of 21
The December 2014 Joinder Motion is the first publication of alleged sexual interaction
between Plaintiff and Prince Andrew. At some point between March 2011 and January 2015,
Churcher requested that Plaintiff handwrite a...
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Declaration dated February 5, 2015, which were filed with the United States District Court for the
Southern District of Florida, in Jane Doe #1 and Jane Doe #2 v. United States of America, Case
No. OS-S0736-CIV-MARRA/JOHNSON, [ECF No. 291-1] (the "Federal Action").” Defendant
should not...
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...logs-reveal-time-trips-Bill-Clinton-Harvard-law-professor-Alan-
Dershowitz-took-pedophile-Jeffrey-Epstein-s-Lolita-Express-private-jet-anonymous-
women.html (January 22, 2015).
® See McCawley Decl. at Exhibit 11, Detective Joseph Recarey’s June 21, 2016 Dep. Tr. at 29-30.
° See McCawley Decl.at Exhibit 12...
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...Giuffre has alleged, “I flew to the Caribbean with Jeffrey and then Ghislaine
Maxwell went to pick up Bill [Clinton] in a huge black helicopter that Jeffrey had
bought her.” Sara Nathan, Bill Clinton Pictured with Jeffrey Epstein’s Social
Fixer, Daily Mail, (12 January 2015).
As a threshold matter...
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...Maxwell slandered her on January 4, 2015, when
responding to a question posed to her while she was on a Manhattan street. Doc.1 § 37. This
allegedly defamatory statement is addressed in Argument IV, below.
16 Aronson, 483 N.E.2d at 1139.
"James, 353 N.E.2d at 838...
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