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Case 18-2868, Document 280, 08/09/2019, 2628232, Page22 of 74
And, Ms. Giuffre has produced a number of pictures of herself taken at the Zorro Ranch,
Epstein’s New Mexico Ranch, two of which are bel
Case 18-2868, Document 280, 08/09/2019, 2628232, Page9 of 74
L PRELIMINARY STATEMENT
There can be no question that disputed issues of material facts preclude granting
summary judgment when, in a one
Case 18-2868, Document 280, 08/09/2019, 2628232, Page10 of 74
finding that her defamatory press release was actually a legal opinion, issued not by her, but by
her lawyer, to the media, despite docum
Case 18-2868, Document 280, 08/09/2019, 2628232, Page21 of 74
summary judgment — as well as all previous briefing papers — are absolutely silent on those
damning documents.
2. The Photographs
Thro
Case 18-2868, Document 279, 08/09/2019, 2628231, Page37 of 37
CERTIFICATE OF SERVICE
I certify that on February 10, 2017, I electronically served this Reply Brief in Support of
Defendant's Motion fo
Case 18-2868, Document 280, 08/09/2019, 2628232, Page1 of 74
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwel
Case 18-2868, Document 279, 08/09/2019, 2628231, Page33 of 37
Under New York law, a defendant’s allegedly defamatory statement is held “to a standard
of substantial, not literal, accuracy.” Law Firm
Case 18-2868, Document 279, 08/09/2019, 2628231, Page32 of 37
took her to Mr. Epstein’s bedroom; during the massage that woman gave instructions to plaintiff,
and the massage “quickly developed into
Case 18-2868, Document 279, 08/09/2019, 2628231, Page19 of 37
In the case at bar, application of the four Steinhilber factors on the Rule 56 record
compels a different conclusion. The complaint alleg
Case 18-2868, Document 279, 08/09/2019, 2628231, Page23 of 37
recipients that they republished plaintiff's obvious falsehoods against Ms. Maxwell at their legal
peril. See id. JJ 13, 16, 17, 20.
As
Case 18-2868, Document 279, 08/09/2019, 2628231, Page25 of 37
Ill. The pre-litigation privilege bars this action.
A. The privilege applies to the January 2015 statement.
Statements pertinent to a go
Case 18-2868, Document 279, 08/09/2019, 2628231, Page18 of 37
is a mistake. Immuno AG is the seminal case prescribing the analysis to be used in a summary-
judgment proceeding for assessing whether u
Case 18-2868, Document 279, 08/09/2019, 2628231, Page15 of 37
media were selective, partial republications of the statement. Any such selective, partial
republication by definition took those excerpt
Case 18-2868, Document 279, 08/09/2019, 2628231, Page16 of 37
behavior is that of a liar, i.e., one who increasingly embellishes her story, and her allegations
become more and more outlandish, so tha
Case 18-2868, Document 279, 08/09/2019, 2628231, Page17 of 37
She objects he is “non-deposed.” But Mr. Barden was the third-listed potential witness in
our Rule 26(a)(1)(A) disclosure, served on plai
Case 18-2868, Document 279, 08/09/2019, 2628231, Page13 of 37
question: whether Ms. Maxwell affirmatively authorized or requested a person or entity “over
whom [s]he has . . . control,” 938 N.E.2d at
Case 18-2868, Document 279, 08/09/2019, 2628231, Page10 of 37
This argument, too, is frivolous. Despite plaintiff's baseless claim there is an “old”
formulation and a “more modern” formulation of rep
Case 18-2868, Document 279, 08/09/2019, 2628231, Page1 of 37
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
cane xX
VIRGINIA L. GIUFFRE,
Plaintiff,
v.
15-cv-07433-RWS
GHISLAINE MAXWEL
oo O© Oa NO aA FF WO ND =
yO = = =&@ 3=@ =&o& & & & o& oa
oOo Oa NOOO BF OULD
21
22
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24
25
Case 18-2868, Document 278, 08/09/2019, 2628230, Page536 of 648
ALSO PRESENT
Edward J. Pozzuoli, Speci
Case 18-2868, Document 278, 08/09/2019, 2628230, Page528 of 648
ase 1:15-cv-07433-RWS Document 435-3 Filed 09/15/16 Page 2 of 6
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BRO
Case 18-2868, Document 278, 08/09/2019, 2628230, Page522 of 648
Page 303
JOSEPH RECAREY - CONFIDENTIAL
went to New York but on a commercial flight. Does
that jog your memory?
MS. SCHULTZ: Object to
Case 18-2868, Document 278, 08/09/2019, 2628230, Page524 of 648
Page 305
JOSEPH RECAREY - CONFIDENTIAL
have been outside of the country with Mr. Epstein,
ever, correct?
MS. SCHULTZ: Object to the f
Case 18-2868, Document 278, 08/09/2019, 2628230, Page512 of 648
Page 259
JOSEPH RECAREY - CONFIDENTIAL
Q. Any way that you get contacted by a police
officer, if they put it into your database, it wi
Case 18-2868, Document 278, 08/09/2019, 2628230, Page508 of 648
Page 215
H RECAREY - CONFIDENTIAL
MS. SCHULTZ: Object to form, foundation.
THE WITNESS: JI don't recall.
BY MR. PAGLIUCA:
Q. If some
Case 18-2868, Document 278, 08/09/2019, 2628230, Page513 of 648
Page 260
JOSEPH RECAREY - CONFIDENTIAL
Have you ever talked to her?
A. I don't recall.
Q. Do you know what information that she may
Case 18-2868, Document 278, 08/09/2019, 2628230, Page503 of 648
Page 203
JOSEPH RECAREY - CONFIDENTIAL
That would be one. Probably victim JB would be
another. I believe there was a victim ML, as wel
Case 18-2868, Document 278, 08/09/2019, 2628230, Page501 of 648
Page 195
JOSEPH RECAREY - CONFIDENTIAL
as part of this case, right?
A. Correct, because it was between two
consenting adults.
Q. Exa
Case 18-2868, Document 278, 08/09/2019, 2628230, Page493 of 648
Page 187
JOSEPH RECAREY - CONFIDENTIAL
Q. Okay. The person alleged to have brought
the alleged victim No. 1 to Mr. Epstein's house is
Case 18-2868, Document 278, 08/09/2019, 2628230, Page494 of 648
Page 188
JOSEPH RECAREY - CONFIDENTIAL
have spoken to Ms. Maxwell ever, correct?
MS. SCHULTZ: Object to form.
THE WITNESS: It's been
Case 18-2868, Document 278, 08/09/2019, 2628230, Page502 of 648
Page 196
H RECAREY - CONFIDENTIAL
THI ESS: Either in the report or on
the tapes.
BY MR. PAGLIUCA:
Q. That's an interesting point, so
Case 18-2868, Document 278, 08/09/2019, 2628230, Page490 of 648
Page 180
JOSEPH RECAREY - CONFIDENTIAL
Exhibit 1. Are you with me?
A. Uh-huh.
Q. Okay. Again, this was information that
was obtained
Case 18-2868, Document 278, 08/09/2019, 2628230, Page488 of 648
Page 11
JOSEPH RECAREY - CONFIDENTIAL
investigator over a case, is to acclimate yourself
to the history of the case?
MR. PAGLIUCA: Ob
Case — we 278; 08/09/2019, —— jon of 648
JB :
Case No.: 00~-11425CF A02 “pt ST of FL vs. ANTHONY LUIS ZAC FIGUEROA
Charges: GRAND THEFT (MOTOR VEHICLE)
Arrest# __ 2000346620 Bond# _P07-00274775 Type
Case 18-2868, Document 278, 08/09/2019, 2628230, Page486 of 648
Deposition Exhibit 10
Investigative report
Deposition Exhibit 11
CD with audio recording (retained by Boies)
Deposition Exhibit 11
S
Case a | Document 278; 08/09/2019, ~~ Page470 of 648
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, STATE OF FLORIDA
CRIMINAL DIVISION "W" (CGS)
STATE OF FLORID
- Case Sa 278, 08/09/2019, 2628230, Page475 of 648
In the Circuit Court of the Fifteenth Judicial Circuit
In and For Palm Beach County, Florida
. O07 O(°ZVS ee Hew
Case No.
Division: WwW
STATE OF
Case 18-2868, DgPrrent 278, 08/09/2019, 2628230, é of 648
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CRIMINAL DIVISION
DS JASON VANDUSEN, 6142
PALM
. Case “wo 278,,08/09/2019, or of 648
PLEA IN THE CIRCUIT COURT
THE FOLLOWING IS TO REFLECT ALL TERMS OF THE NEGOTIATED SETTLEMENT
N .
Name: LEN Zac. Fre lag 09
Plea: Guilty 7Guilty/Bds} Interest __
Case — we 278, 08/09/2019, 2628230, Page463 of 648
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, STATE OF FLORIDA
CRIMINAL DIVISION "W" (CGS)
STATE OF FLORIDA
Case 18-2868, Document 278, 08/09/2019, 2628230, Page444 of 648
Confidential
Page 8
DAVID RODGERS
MR. EDWARDS: That is what I have on the
page.
MR. PAGLIUCA: My last page is 2008 on
copy, 093 Bates
Case 18-2868, Document 278, 08/09/2019, 2628230, Page443 of 648
Confidential
DAVID RODGERS
BY MR. EDWA
(e) : You can keep this -- that down
Okay.
-- so we can keep track of the exhibits.
A. Oka
Case 18-2868, Document 278, 08/09/2019, 2628230, Page445 of 648
Confidential
Page 9
DAVID RODGERS
says. It could have been possibly a later date.
Most likely, fairly close to that date.
Q. Okay. H
OQS - Viewing GaselNurebs, BO¢H32dnt 278, 08/09/2019, 2628230, Page328 of 648 Page 1 of 2
PALM BEACH COUNTY SHERIFF'S OFFICE PAGE 1
CASE NO. 02075321 OFFENSE REPORT CASE NO. 02075321
DISPOSITION: ZUL
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Case 18-2868, Document 278, 08/09/2019, 2628230, Page221 of 648
UNITED STATES DISTRICT COURT
for the
Southern District of New York
Civ
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Case 18-2868, Document 278, 08/09/2019, 2628230, Page222 of 648
INDEX
WITNESS:
Sky Roberts
Di
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Case 18-Agtem Randa: Sourt Rene ntia® & Vide op FA6: 87 of 648
DESCRIPTION
Exhibit 1
Exhibit 2
Exhibit 3
Exhibit 4
Exhibit 5
Exhibit 6
Exhibit 7
Exhibit 8
Exhibit 9
Exhibit 10
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Case 18-Agtem Randa: Sourt Renentia® & Vide op FAG: 88 of 648
DESCRIPTION
Exhibit
Exhibit
Exhibit
Exhibit
Exhibit
Exhibit
15
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17
18
19
20
INITIAL
REFERENCE
Pati
Case 18-2868, Document 278 08/09/2019, Pose eR Rime 8 of 648
eposition of Tony Figuer
144
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BY MS. MENNINGER:
Q Mr. Figueroa, you mentioned that you and
Ms. Roberts attempted
Case 18-2868, Document 278. 08/ Orten 2928 R20 ages? of 648
eposition o igueroa
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INDEX OF EXHIBITS
(MARKED BY THE DEFENDANT: )
Defendant's Exhibit 1 42
Palm Beach County She
10
11
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Case 18-Agrem Banda Court Repo ntiag, 8 Yideop FAC: 30 of 648
DESCRIPTION
INDEX OF EXHIBITS
INITIAL
REFERENCE
Complaint and Demand fo