Epstein Secrets

stituting fault as judged by, at a minimum, a negligence standard, and, it must either cause special harm or constitute defamation per se." 5 Under New York's choice-of-law rules for defamation actions, the general rule is that "the state of the plaintiff's domicile (in this case, Colorado) will usually ha

than does Colorado. Nonetheless, the laws of Colorado and New York are substantially similar. For these reasons, Ms. Maxwell asks the Court to apply New York law, but will note any differences between the two laws when applicable. 7 EFTA00595594 Case 1:15-cv-07433-RWS Document 15 Filed 12/01/15 Page 13

eaders." Menninger Decl. Ex. C at 4-5. On April 7, 2015, U.S. District Court Judge Marra denied Plaintiff's Joinder Motion, ordered the portions of the Joinder Motion pertaining to non-parties Although the Complaint does not explicitly mention the 2011 Statement, it appears Plaintiff believes it to be the "additi

ty-five thousand dollars ($75,000), exclusive of interest and costs. 26. This Court has personal jurisdiction over Defendant. Defendant resides in New York City; Defendant conducts regular business in New York City; and this action arose, defamatory statements were made, and abuse occurred, within the Southe

dent, Plaintiff was under the age of 18. Epstein had taken her from her home, family, and friends in Palm Beach, Florida, and flown her to New York, New York, where he repeatedly sexually abused her. In the weeks immediately prior to the incident, Defendant had met Plaintiff in circumstances that would ha

ationally televised news interviews, wrongfully claimed that Edwards and Cassell had engaged in unethical behavior warranting disbarment for filing the Joinder Motion that described Defendant's involvement with Epstein and Plaintiff. Edwards, who is a prominent lawyer for sexually abused women and children, and Ca

eeds seventy-five thousand ($75,000), exclusive of interest and costs. 25. This Court has personal jurisdiction over Defendant. Defendant resides in New York City; Defendant conducts regular business in New York City; and this action arose, HOUSE_OVERSIGHT_017941 Case 1:19-cv-03377 Document 1 Filed 04/16/19 P

nationally televised news interviews, wrongfully claimed that Edwards and Cassell had engaged in unethical behavior warranting disbarment for filing the Joinder Motion that described Dershowitz’s involvement with Epstein and Roberts. Edwards, who is a prominent attorney for sexually abused women and children, and Ca