Epstein Files Search

EFTA01093254Set 9

2015-10-0938p15,352w

Tamara Green filed a complaint alleging that William H. Cosby, Jr. ("Defendant') publicly defamed her in statements made by individuals operating at his direction and/or within the scope of their ... matter and considered the written filings. II. JURISDICTION The SAC contains three defamation counts brought pursuant to state law. Defamation is not actionable under federal law. Federal courts have jurisdiction ... article submitted by the defendant which had formed the basis of the defamation action, as it was central to the plaintiffs complaint). Additionally, the court uses the full text version

https://www.justice.gov/epstein/files/DataSet%209/EFTA01093254.pdf

EFTA00802274Set 9

93p24,451w

respond to the following question: 9. What is the level of dissemination of defaming statements associating Mr. Bradley J Edwards with the illegal activities of Mr. Scott Rothstein ... activities of Mr. Rothstein as a result of Mr. Epstein's lawsuit as the defaming statements, the statements, or the defaming statements associatingMr. Edwards with Rothstein's illegal activities ... defaming statements associate Mr. Edwards with the illegal activities of a Mr. Scott Rothstein, who is a "notorious Ponzi scheme?". Now a debarred lawyer, he is serving a 50- year

https://www.justice.gov/epstein/files/DataSet%209/EFTA00802274.pdf

EFTA00601577Set 9

93p24,446w

respond to the following question: 9. What is the level of dissemination of defaming statements associating Mr. Bradley J Edwards with the illegal activities of Mr. Scott Rothstein ... activities of Mr. Rothstein as a result of Mr. Epstein's lawsuit as the defaming statements, the statements, or the defaming statements associatingMr. Edwards with Rothstein's illegal activities ... defaming statements associate Mr. Edwards with the illegal activities of a Mr. Scott Rothstein, who is a "notorious Ponzi scheme?". Now a debarred lawyer, he is serving a 50- year

https://www.justice.gov/epstein/files/DataSet%209/EFTA00601577.pdf

EFTA00801709Set 9

94p18,309w

Honor. 19 That is, why do we need affirmative 20 defenses that sound in defamation, and they 21 do. The reason they do is because the 22 counter-plaintiff ... According to the Supreme Court, our 2 complaint is protected. We cannot commit 3 defamation. We cannot commit any action 4 that's based on wrongful words. The only ... expert wants to do. 5 The assignment was the level of 6 dissemination of defaming statements -- 7 defaming statements. That's on page three. 8 Page four. I refer

https://www.justice.gov/epstein/files/DataSet%209/EFTA00801709.pdf

EFTA00595583Set 9

2015-11-3029p8,962w

Litigation Privilege Protects Ms. Maxwell's Statements 14 II. PLAINTIFF FAILED TO PLAUSIBLY PLEAD DEFAMATION 17 A. Viewed In Context, the Statements are Non-Actionable 18 B. The Complaint Does ... issued general denials to the allegations. Those two denials form the basis of this defamation action: Plaintiff claims it defamatory for Ms. Maxwell to have issued statements through her London ... such as Ms. Maxwell's privileged under the law and requires dismissal of this defamation action. As one commentator wrote in 1881, "If I am attacked in a newspaper

https://www.justice.gov/epstein/files/DataSet%209/EFTA00595583.pdf

EFTA00613391Set 9

2016-02-0150p13,597w

Second Amended Counterclaim, attached as Exhibit A, which includes (a) two additional counts for defamation against Plaintiffs / Counterclaim Defendants Bradley J. Edwards ("Edwards") and Paul G. Cassell ("Cassell") (together, "Plaintiffs ... additional, recently discovered facts in support of Dershowitz's defamation claims, as well as (c) a claim for punitive damages. INTRODUCTION & EXECUTIVE SUMMARY As set forth in Dershowitz's First ... Joinder Motion. Based on this conduct, the First Amended Counterclaim asserts two counts of defamation. The Court should now grant Dershowitz leave to file the proposed Second Amended Counterclaim, which

https://www.justice.gov/epstein/files/DataSet%209/EFTA00613391.pdf

EFTA00801596Set 9

35p24,676w

Honer. IS That is, why do we need affirmative 20 defenses that sound in defamation, and they 21 do. The reason they do is because the 22 counter-plaintiff ... complaint is protected. ft cannot commit 3 it makes sense -- that if the litigation defamation. No cannot commit any action 4 privilege applied to the elements of a that ... assignment was the level of 6 investigation, filing a criminal complain: dissemination of defaming statements -- 7 in and of itself can cause injury to your defaming statements. That

https://www.justice.gov/epstein/files/DataSet%209/EFTA00801596.pdf

EFTA00803113Set 9

2017-03-31158p39,273w

sense, perhaps wrongly, that 11 the plaintiff's position was that the defamation was the truth 12 or falsity of the statements relating to the defendant. 13 Period ... client can only be SOUTHERN DISTRICT REPORTERS, P.C. EFTA00803117 H3VOGIU1 1 alleged to have defamed someone based on facts, not opinions. 2 THE COURT: Agreed. Agreed. 3 MS. MENNINGER ... with respect to the summary judgment, each individual 25 is responsible for their own defamation, so it doesn't come SOUTHERN DISTRICT REPORTERS, P.C. EFTA00803128 H3VOGIU1 17 1 into consideration

https://www.justice.gov/epstein/files/DataSet%209/EFTA00803113.pdf

EFTA00612250Set 9

2017-03-31158p38,362w

sense, perhaps wrongly, that 11 the plaintiff's position was that the defamation was the truth 12 or falsity of the statements relating to the defendant. 13 Period ... SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00612254 H3VOGIU1 1 alleged to have defamed someone based on facts, not opinions. 2 THE COURT: Agreed. Agreed. 3 MS. MENNINGER ... with respect to the summary judgment, each individual 25 is responsible for their own defamation, so it doesn't come SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00612265 H3VOGIU1

https://www.justice.gov/epstein/files/DataSet%209/EFTA00612250.pdf

EFTA01250720Set 9

23p3,969w

Jeffrey Epstein accuser emerges: defamation suit filed I Miami Herald NATION & WORLD New Jeffrey Epstein accuser goes public; defamation lawsuit targets Dershowitz BY IF: K. BROWN APRIL ... www.miantiherald.cornfnewsfnation-world/article229277874.MmIl5/17/20I9 1:47:04 P841 EFTA_00102213 EFTA01250720 New Jeffrey Epstein accuser emerges: defamation suit filed I Miami Herald A new victim has gone public in the Jeffrey Epstein ... www.miamiherald.corninews/nation-world/article229277874.Mm115/17/2019 1:47:04 PM' EFTA_00102214 EFTA01250721 New Jeffrey Epstein accuser emerges: defamation suit filed i Miami Herald "To my knowledge, I was the first person to report

https://www.justice.gov/epstein/files/DataSet%209/EFTA01250720.pdf

EFTA01099134Set 9

2015-03-0226p11,196w

Edwards and Cassell. In response, Dershowitz has filed a counterclaim alleging two counts of defamation by Edwards and Cassell: Count I, concerning statements in a pleading filed in federal court ... both the fair report privilege and the litigation privilege. BACKGROUND The events underlying this defamation case arise from a lawsuit filed by attorneys Edwards and Cassell ... January 6, 2015, Edwards and Cassell filed this action, alleging that Dershowitz had defamed them by attacking their honesty and integrity in the course of their representation of their client

https://www.justice.gov/epstein/files/DataSet%209/EFTA01099134.pdf

EFTA00591577Set 9

2015-12-2813p3,821w

TABLE OF CONTENTS INTRODUCTION ARGUMENT I. PLAINTIFF FAILED TO PLAUSIBLY PLEAD DEFAMATION A. Plaintiff Failed to Adequately Plead a Defamation Claim 1 B. Ms. Maxwell's Statement In Context ... Document 25 Filed 12/28/15 Page 3 of 13 INTRODUCTION The primary focus of any defamation claim should be the alleged defamatory statements themselves. But Ms. Maxwell's statements have never ... consideration—whether Ms. Maxwell's statements are truly defamatory, whether Plaintiff properly pled a defamation claim, and whether Ms. Maxwell was privileged to make her statements—Plaintiff spends the bulk

https://www.justice.gov/epstein/files/DataSet%209/EFTA00591577.pdf

EFTA00623075Set 9

2016-06-0140p11,688w

Florida Court Rejects a Waiver of Attorney Clients Privilege Argument 5 Deposition in the Defamation Case 7 The Settlement of the Defamation Case 7 LEGAL STANDARDS FOR WAIVER ... WAIVE HER ATTORNEY-CLIENT PRIVILEGE WHEN EDWARDS AND CASSELL FILED AND PURSUED THEIR OWN DEFAMATION ACTION AGAINST ALAN DERSHOWITZ 14 A. The Florida Court Presiding over the Defamation Action ... Live (Jan. 5, 2015).5 Cassell and Edwards then filed a state law defamation action against Dershowitz in Broward County, Florida. See McCawley Decl., Exhibit. 5, Complaint in Edwards

https://www.justice.gov/epstein/files/DataSet%209/EFTA00623075.pdf

EFTA00794556Set 9

2017-03-31159p41,795w

sense, perhaps wrongly, that 11 the plaintiff's position was that the defamation was the truth 12 or falsity of the statements relating to the defendant. 13 Period ... SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00794560 6 H3VOGIU1 1 alleged to have defamed someone based on facts, not opinions. 2 THE COURT: Agreed. Agreed. 3 MS. MENNINGER ... with respect to the summary judgment, each individual 25 is responsible for their own defamation, so it doesn't come SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00794571 17 H3VOGIU1

https://www.justice.gov/epstein/files/DataSet%209/EFTA00794556.pdf

EFTA00100685Set 9

2019-10-1616p10,633w

Cases that cite this headnote Synopsis Background: Plaintiff brought action alleging that defendant defamed her by making public statements that she was liar, had committed perjury, and was conspiring with ... Cases that cite this headnote New York's single publication rule is that defamation claim accrues at publication, defined as earliest date on which work was placed on sale ... which statute of 1111 Libel and Slander...Existence and Effect of limitations for defamation claim commences Malice upon original publication. Under New York law, either constitutional malice or common

https://www.justice.gov/epstein/files/DataSet%209/EFTA00100685.pdf

EFTA00805442Set 9

2011-10-0416p4,481w

fact, and states: INTRODUCTION Edwards is Attempting to Recover Damages Based on a Defamation Action Despite protestations to the contrary and this Court's rulings, Edwards plans to seek damages ... based on a defamation action. Edwards' expert confirms this and Edwards has illustrated this in both statements made to the Court and in discovery: • March 24. 2011: In his Case ... Florida law conclusively presumes the damages that inevitably arises from such defamation. The false accusations have been disseminated repeatedly throughout not only the South Florida legal community but nationally

https://www.justice.gov/epstein/files/DataSet%209/EFTA00805442.pdf

EFTA01089041Set 9

2015-03-028p4,992w

Edwards and Cassell. In response, Dershowitz has filed a counterclaim alleging two counts of defamation by Edwards and Cassell: Count I, concerning statements in a pleading filed in federal court ... both the fair report privilege and the litigation privilege. BACKGROUND The events underlying this defamation case arise from a lawsuit filed by attorneys Edwards and Cassell ... January 6, 2015, Edwards and Cassell filed this action, alleging that Dershowitz had defamed them by attacking their honesty and integrity in the course of their representation of their client

https://www.justice.gov/epstein/files/DataSet%209/EFTA01089041.pdf

EFTA01079203Set 9

2016-01-1260p13,979w

Action"). After Dershowitz defended himself to the media, Edwards and Cassell sued Dershowitz for defamation. The falsity of allegations, her credibility, and the investigation her lawyers took to assess those ... goal of deposing Jane Doe No. 3 has nothing to do with this Florida Defamation Action; rather, he is trying to find a way to send this victim of sexual ... bringing a lawsuit against Jane Doe No. 3. "And we're considering suing herfor defamation as well, but right now she was trying to hide in Colorado and avoid service

https://www.justice.gov/epstein/files/DataSet%209/EFTA01079203.pdf

EFTA00603608Set 9

2015-01-06129p34,335w

Interrogatories. In support of this motion, Dershowitz states as follows: BACKGROUND Plaintiffs filed this defamation action against Dershowitz on January 6, 2015. In their Complaint, Plaintiffs allege that Dershowitz defamed ... protection that would otherwise attach to responsive documents and information by bringing this defamation action and placing at issue the truthfulness of Jane Doe No. 3's allegations against Dershowitz ... Dershowitz's Discovery Requests seeking these categories of information and documents. By filing this defamation action and placing at issue both the truthfulness of Jane Doe No. 3's allegations

https://www.justice.gov/epstein/files/DataSet%209/EFTA00603608.pdf

EFTA01085801Set 9

2014-02-0639p15,763w

other jurisdictions . . . hold that even where an absolute privilege bats an action for defamation based on statements made during a judicial proceeding, it does not bar an action for malicious ... fact that a communication may be absolutely privileged for the purposes of a defamation action does not prevent its being an element of an action for malicious prosecution ... policy of encouraging free access to the courts that underlies the privilege applicable in defamation actions is outweighed by the policy of affording redress for individual wrongs when the requirements

https://www.justice.gov/epstein/files/DataSet%209/EFTA01085801.pdf