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746 KB
Extraction Summary
5
People
3
Organizations
1
Locations
3
Events
3
Relationships
5
Quotes
Document Information
Type:
Court filing (legal memorandum/brief)
File Size:
746 KB
Summary
This document is page 8 of a defense filing (Case 1:20-cr-00330-AJN) dated February 4, 2021, arguing that Virginia Giuffre's defamation claims against Ghislaine Maxwell were based on lies and that Giuffre attempted to shift the focus to being 'sexually trafficked' by Epstein to third parties. It details the legal history of Maxwell's depositions and a protective order granted to shield confidential information from a 'media circus.' A footnote references a concurrent lawsuit between Giuffre and Alan Dershowitz, noting Dershowitz filed evidence suggesting Giuffre and her lawyers fabricated stories.
People (5)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the filing; defending against defamation claims; deposed twice.
|
| Virginia Giuffre | Plaintiff/Accuser |
Made allegations of trafficking; plaintiff in defamation suits against Maxwell and Dershowitz.
|
| Jeffrey Epstein | Alleged Trafficker |
Accused of sexually trafficking Giuffre to other men.
|
| Alan Dershowitz | Professor/Defendant |
Defendant in a separate defamation suit by Giuffre; counter-suing Giuffre; filed affidavit suggesting Giuffre fabrica...
|
| Unnamed Reporter | Witness/Source |
Person to whom Giuffre sold her story; allegedly revealed belief that Giuffre fabricated evidence.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Court |
Granted protective order; hearing the cases.
|
|
| Law Enforcement |
Giuffre sought exception to protective order for investigations by law enforcement.
|
|
| Department of Justice |
Implied by Bates stamp 'DOJ-OGR'.
|
Timeline (3 events)
Unknown
Locations (1)
| Location | Context |
|---|---|
|
Reference to the separate legal proceedings involving Dershowitz.
|
Relationships (3)
Opposing parties in defamation suit; Maxwell claims Giuffre lied.
Involved in defamation suit and counter-suit (Case No. 19-cv-3377-LAP).
Linked in allegations of trafficking; Giuffre sold story about both.
Key Quotes (5)
"“trafficked” to third party dignitaries, politicians and academics."Source
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"Ms. Giuffre had publicly made allegations that were “untrue” and “obvious lies”"Source
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Quote #2
"Giuffre was “sexually trafficked” by Epstein to other men."Source
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Quote #3
"what was sure to be a high-publicity, media circus."Source
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Quote #4
"reporter to whom Ms. Giuffre sold her story about Epstein and Maxwell revealing that she believes Ms. Giuffre and her lawyers fabricated evidence"Source
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,253 characters)
Case 1:20-cr-00330-AJN Document 136 Filed 02/04/21 Page 8 of 27
“trafficked” to third party dignitaries, politicians and academics.³ Suffice it to say, had the
defamation matter proceeded to trial, Ms. Maxwell would have had no difficulty demonstrating
that Ms. Giuffre had publicly made allegations that were “untrue” and “obvious lies,” defeating
any civil liability.
defamation matter proceeded to trial, Ms. Maxwell would have had no difficulty demonstrating
that Ms. Giuffre had publicly made allegations that were “untrue” and “obvious lies,” defeating
any civil liability.
Because Giuffre could not prove the truth of her own statements, she and her lawyers
attempted to convert what should have been a relatively straightforward factual question—the
truth of Ms. Maxwell’s denial of Giuffre’s fantastical allegations—into a claim that Giuffre was
“sexually trafficked” by Epstein to other men. This attempt, however, involved inadmissible and
improper evidence, which was the subject of approximately 50 motions that remained undecided
at the time that the defamation action was dismissed.
attempted to convert what should have been a relatively straightforward factual question—the
truth of Ms. Maxwell’s denial of Giuffre’s fantastical allegations—into a claim that Giuffre was
“sexually trafficked” by Epstein to other men. This attempt, however, involved inadmissible and
improper evidence, which was the subject of approximately 50 motions that remained undecided
at the time that the defamation action was dismissed.
B. Ms. Maxwell’s Depositions
It is in this context—a weak defamation claim—that Ms. Maxwell was deposed twice.
Before her first deposition, however, the Court granted at Ms. Maxwell’s request a protective
order to shield any “confidential” information from what was sure to be a high-publicity, media
circus. Case No. 15-cv-7433, Doc. # 38. Plaintiff opposed Ms. Maxwell’s proposed protective
order, instead urging the Court to permit disclosure of “confidential” information in relation to
“investigations by law enforcement.” Id., Doc. # 40 at 3-4. Ms. Maxwell opposed this
provision, and ultimately, the Protective Order was entered without Giuffre’s proposed law
enforcement exception. Ex. G.
Before her first deposition, however, the Court granted at Ms. Maxwell’s request a protective
order to shield any “confidential” information from what was sure to be a high-publicity, media
circus. Case No. 15-cv-7433, Doc. # 38. Plaintiff opposed Ms. Maxwell’s proposed protective
order, instead urging the Court to permit disclosure of “confidential” information in relation to
“investigations by law enforcement.” Id., Doc. # 40 at 3-4. Ms. Maxwell opposed this
provision, and ultimately, the Protective Order was entered without Giuffre’s proposed law
enforcement exception. Ex. G.
__________________
³ At present in a neighboring courtroom, Ms. Giuffre is embroiled in another defamation suit, this
time against Professor Alan Dershowitz. See Giuffre v. Dewrshowitz, Case No. 19-cv-3377-LAP. But
Professor Dershowitz has counterclaimed against her for defamation and related torts. Id. Doc. # 90 &
127. In that matter, Professor Dershowitz recently filed an affidavit and transcript which document the
reporter to whom Ms. Giuffre sold her story about Epstein and Maxwell revealing that she believes Ms.
Giuffre and her lawyers fabricated evidence including her story about Professor Dershowitz. Id. at Doc. #
210-1, 210-2.
³ At present in a neighboring courtroom, Ms. Giuffre is embroiled in another defamation suit, this
time against Professor Alan Dershowitz. See Giuffre v. Dewrshowitz, Case No. 19-cv-3377-LAP. But
Professor Dershowitz has counterclaimed against her for defamation and related torts. Id. Doc. # 90 &
127. In that matter, Professor Dershowitz recently filed an affidavit and transcript which document the
reporter to whom Ms. Giuffre sold her story about Epstein and Maxwell revealing that she believes Ms.
Giuffre and her lawyers fabricated evidence including her story about Professor Dershowitz. Id. at Doc. #
210-1, 210-2.
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