Search results for 08-09-2019
1,806 results for "08-09-2019"
Page 58 of 73
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Court Filing
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 republication-liability law in New York, both
cases she cites applied the same “old” standard used by...
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Court Filing
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 excerpts “out of context.” This is so because Mr. Gow
informed the media in his email that he was providing “a...
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Court Filing
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-count defamation case, Defendant presents the Court with a
68-page memorandum of law, a 16...
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Case 18-2868, Document 280, 08/09/2019, 2628232, Page36 of 74
attacks. If accepted, this remarkable claim would eviscerate defamation law, as it would permit a
defamer to send defamatory statements to the media and then stand back and watch — immune
from liability — when (as in this case) the...
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Court Filing
Case 18-2868, Document 280, 08/09/2019, 2628232, Page58 of 74
States Supreme Court, and reiterated by the Second Circuit, should be the light by which all of
Defendant’s purported “facts” and argument should be viewed. “Actual malice” means that the
statement was published with “knowledge that the...
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Email
Case 18-2868, Document 281, 08/09/2019, 2628234, Page11 of 66
CVRA action could strike the “lurid details” of Ms. Giuffre’s allegations in the joinder
motion, members of the media obtained copies of the motion.
MS. GIUFFRE’S STATEMENT CONTROVERTING DEFENDANT?’S FACTS
See Ms. Giuffre’s Response...
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Court Filing
Case 18-2868, Document 281, 08/09/2019, 2628234, Page33 of 66
While “Grade 30” indicates adult education, Ms. Giuffre’s attendance records indicate that she
was not present in school between 6/21/00-09/20/01 (see withdrawal codes W32 and W47).
WITHDRAWAL CODES: ADULT STUDENTS
e W26...
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Legal
Case 18-2868, Document 284, 08/09/2019, 2628244, Page29 of 38
incurring a phone bill of $4,000. Ex.P at 35. She met Robert Giuffre while in Thailand and
decided to marry him. She thereafter ceased all contact with Figueroa from October 2002 until
two days before Mr...
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Court Filing
Case 18-2868, Document 276, 08/09/2019, 2628224, Page40 of 77
trafficking. Viewing the July 2015 statement from the perspective of these reporters and
journalists—the only persons who received the July 2015 statement—presents a different
landscape in the “fact versus opinion” analysis.
Applying the third factor with...
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Case 18-2868, Document 278, 08/09/2019, 2628230, Page272 of 648
Policy:
All employees with a minimum of 12 months of service (and
1250 or more hours worked during the previous 12 months) at the
time the family medical LOA begins, are eligible for up to 12
weeks of...
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Court Filing
Case 18-2868, Document 281, 08/09/2019, 2628234, Page51 of 66
From September 29, 2002 through October 19, 2002, Defendant and Epstein sent Ms.
Giuffre on a commercial flight to Thailand for massage training and provided her with all
accommodations. See McCawley Dec. at Exhibit 43, Giuffre00741 1-Giuffre007432...
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Court Filing
Case 18-2868, Document 276, 08/09/2019, 2628224, Page11 of 77
said the striking of the “lurid details” was a sanction for Ms. Giuffre’s improper inclusion of
them in the motion. See id. at 6-7.
10. The district court found not only that the “lurid details” were...
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Court Filing
Case 18-2868, Document 276, 08/09/2019, 2628224, Page38 of 77
forceful argument that plaintiff's shifting and inconsistent stories about what allegedly happened
rendered her inherently unbelievable and proved her increasingly provocative and lurid
allegations were “obvious lies.” These are precisely the messages Mr. Barden sent to them...
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Case 18-2868, Document 278, 08/09/2019, 2628230, Page88 of 648
she is, since both statements cannot as a matter of fact be true. When someone says she did not
have sex and then says she did, in other words, there is an obvious lie.
15. I did not...
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Case 18-2868, Document 278, 08/09/2019, 2628230, Page89 of 648
press to stop and think before publishing, to cease and desist, and that if they continued then they
faced higher damages for ignoring my clear warning.
19. Consistent with those two purposes, Mr. Gow’s emails prefaced the...
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Case 18-2868, Document 278, 08/09/2019, 2628230, Page293 of 648
IF YOU LEAVE EMPLOYMENT
RESIGNATION POLICY
When an employee decides to leave for any reason, his/her
supervisor and the Human Resources Manager would like the
opportunity to discuss the resignation before final action is
taken. The Mar...
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Case 18-2868, Document 279, 08/09/2019, 2628231, Page3 of 37
TABLE OF AUTHORITIES
Cases
Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249 (1986). ...cscsscsscsescesseeeeeeseeseeseeeeseeaeees 9
Blair y. Inside Ed. Prods., 7 F. Supp. 3d 348, 358 & n.6 (S.D.N.Y. 2014) wee eeeeeee 25...
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Page 3743
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DATE: _ 08/09/2019
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Case 18-2868, Document 280, 08/09/2019, 2628232, Page68 of 74
investigators from the FBI) did not know about Defendant’s sex trafficking. This proof would
need to include, for example, evidence that the FBI did not learn about Defendant’s sex
trafficking when (among other things) Ms. Giuffre...
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Court Filing
Case 18-2868, Document 281, 08/09/2019, 2628234, Page63 of 66
60. Virginia worked at Mar-a-Lago as a spa bathroom attendant. See McCawley Dec.
at Exhibit 5, Giuffre Dep. Tr. at 61:9-61:24; Austrich Dep. Tr. at 100:3-12.
61. Virginia was not a...
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Case 18-2868, Document 276, 08/09/2019, 2628224, Page30 of 77
from the whole scope and apparent object of the writer.” James v. Gannett Co., 353 N.E.2d 834,
838 (N.Y. 1976); accord, e.g., Chau v. Lewis, 935 F. Supp. 2d 644, 665 (S.D.N...
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Court Filing
Case 18-2868, Document 278, 08/09/2019, 2628230, Page90 of 648
were and are “obvious lies.” As noted, her claims not to have slept with Prince Andrew and to
have slept with Prince Andrew are a classic example of an obvious lie. One or other account is
on the...
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Case 18-2868, Document 278, 08/09/2019, 2628230, Page275 of 648
insurance premiums paid by the employer during the
LOA.
(g) An employee on an LOA must notify the Human
Resources Manager of intent to return at least 7
days prior to the desired return date. Medical
certification of...
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Court Filing
Case 18-2868, Document 280, 08/09/2019, 2628232, Page35 of 74
responded by calling her a liar in a press release intended for worldwide publication. Such
heinous conduct is not a mere “opinion,” but rather is defamation executed deliberately and with
actual malice. The jury should hear all of...
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Court Filing
Case 18-2868, Document 280, 08/09/2019, 2628232, Page70 of 74
Defendant maintained the position that she “cannot speculate on what anybody else did or didn’t
do.” See McCawley Dec. at Exhibit 11, Maxwell 4-22-2016 Dep. Tr. at 180:3-180:4. In fact,
regarding Ms...
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