Epstein Secrets

er reputation that factual reporting of what had happened to her would not be credited. 29. As part of Maxwell's campaign she directed her agent, Ross Gow, to attack honesty and truthfulness and to accuse of lying. 30. On or about January 3, 2015, speaking through her authorized agent, Maxwell issu

s Court has personal jurisdiction over Maxwell. Maxwell resides in New York City, and this action arose, and defamatory statements were made, within the Southern District of New York. 5. Venue is proper in this Court as the cause of action arose within the jurisdiction of this Court. 2 EFTA00676991 Case 1:15-cv

endant also "`participat[ed] in the sexual abuse"' of others. Id. A few days later, the press reported a statement by a spokesman for the defendant, Ross Gow. Among other things, 45 =filed a corrected motion on January 2, 2015. See Doe, No. 08 Civ. 80736, Dkt. No.280. The court later struck the original

cedure grant the Court authority to strike surplusage from an indictment, see Fed. R. Crim. P. 7(d), lijt has long been the policy of courts within the Southern District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez,

fendant also "`participat[ed] in the sexual abuse" of others. Id. A few days later, the press reported a statement by a spokesman for the defendant, Ross Gow. Among other things, 45 Giuffre filed a corrected motion on January 2, 2015. See Doe, No. 08 Civ. 80736, Dkt. No. 280. The court later struck the o

cedure grant the Court authority to strike surplusage from an indictment, see Fed. R. Crim. P. 7(d), li]t has long been the policy of courts within the Southern District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez,

fendant also "`participat[ed] in the sexual abuse" of others. Id. A few days later, the press reported a statement by a spokesman for the defendant, Ross Gow. Among other things, 45 Giuffre filed a corrected motion on January 2, 2015. See Doe, No. 08 Civ. 80736, Dkt. No. 280. The court later struck the o

cedure grant the Court authority to strike surplusage from an indictment, see Fed. R. Crim. P. 7(d), li]t has long been the policy of courts within the Southern District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez,

to ain (Mailgjuffre alleged that "participat[ed] in the sexual A few days later, the press reported a statement by a spokesman for the defendant, Ross Gow. Among other things, Gow stated that Giuffre's claims were "untrue" and "obvious lies." (15 Civ. 7433 (LAP), Dkt. No. 1 at 6). 45 Giuffre filed a c

edure grant the Court authority to strike surplusage from an indictment, see Fed. R. Crim. P. 7(d), '[i]t has long been the policy of courts within the Southern District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez,

fendant also "`participat[ed] in the sexual abuse" of others. Id. A few days later, the press reported a statement by a spokesman for the defendant, Ross Gow. Among other things, 45 filed a corrected motion on January 2, 2015. See Doe, No. 08 Civ. 80736, Dkt. No. 280. The court later struck the original

cedure grant the Court authority to strike surplusage from an indictment, see Fed. R. Crim. P. 7(d), li]t has long been the policy of courts within the Southern District to refrain from tampering with indictments."' United States v. Bin Laden, 91 F. Supp. 2d 600, 621 (S.D.N.Y. 2000) (quoting United States v. Jimenez,