Epstein Secrets

/15 Page 1 of 29 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X PLAINTIFF, V. GHISLAINE MAXWELL, DEFENDANT. X 15-cv-07433-RWS GHISLAINE MAXWELL'S MEMORANDUM OF LAW IN SUPPORT OF MOTION TO DISMISS COMPLAINT Laura A. Menninger, Esq. HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Ave

r CO 80203 Tel: Dated: November 30, 2015 EFTA00595583 Case 1:15-cv-07433-RWS Document 15 Filed 12/01/15 Page 2 of 29 Table of Contents I. MS. MAXWELL'S STATEMENTS ARE PRIVILEGED 9 A. The Self-Defense Privilege Protects Ms. Maxwell's Statements 9 B. The Pre-Litigation Privilege Protects Ms. Maxw

attributed statement responds directly to allegations and claims made by Plaintiff. Compl. 1 31. Likewise to the extent the claimed statement that "Ghislaine Maxwell's original response to the lies and defamatory claims remains the same" (Compl. 1 32) refers to an earlier statement describing Plaintiff's "factual

led 12/01/15 Page 2 of 29 Table of Contents I. MS. MAXWELL'S STATEMENTS ARE PRIVILEGED 9 A. The Self-Defen

ises out of the charges he has made against me." William Blake Odgers, A Digest of the Law of Libel and Slander

Symposium. (RTI Press Publication No. CP-0004- 1705). Research Triangle Park, NC: R1'1 Press. DOI: 10.3768/rtipress.2017.cp.0004.1705. 11. LaPorte, GM. (2015) Chemical analysis for the scientific examination of questioned documents, in Forensic Chemistry: Fundamentals and Applications (ed J. A. Sie

rior Court of the State of California County of Los Angeles, Central District Case No.: BC551551 (Related Case BC 550227) October 14/18, 2016 60. William Baker, Sr., Individually, and as an Heir of the Estate of Frederick Tyrone Baker, and Candice Renae Bryan as of Frederick Tyrone Baker, Deceased vs. Timo

, "Appearing via video from his home state, Adam Maxwell Donn, of Norfolk, admitted during a federal court

unity to make oral arguments on whether Trump can substitute the United States for himself as the defendant in her defamation lawsuit." DOJ attorney William Lane told US District Judge Lewis Kaplan that "the government would rest on its papers, meaning it would rely solely on already submitted written argume

s, "Appearing via video from his home state, Adam Maxwell Donn, of Norfolk, admitted during a federal cour

nity to make oral arguments on whether Trump can substitute the United States for himself as the defendant in her defamation lawsuit." DO) attorney William Lane told US District Judge Lewis Kaplan that "the government would rest on its papers, meaning it would rely solely on already submitted written argumen

its?—and work their way backward, molding their perception of reality like Silly Putty in order to cu/minate with the justification of that premise. Maxwell continued: “About ten years ago, a young black man broke into the Queen Mum’ s bedroom, and one of her servants happened to be walking by and the bed

but there's no conspirator--it's the wrong word. That's why | say it's just natural law. It is all perfect.” “Would you agree with the concept--what William Blake said, that humans were created ‘for joy and woe'--the implication of which is that there will always be suffering?” “| think that suffering is part

mbitions for cybernetic concepts, however, and in 7he Human Use of Human Beings he spells out his thoughts on its application to topics as diverse as Maxwell’s Demon, human language, the brain, insect metabolism, the legal system, the role of technological innovation in government, and religion. These broa

e are human ones. But there is no reason to suppose that an AGI created in a society consisting primarily of decent citizens, and raised without what William Blake called “mind-forg’d manacles,” will in general impose such manacles on itself (1.e., become irrational) and/or choose to be an enemy of civilization.

mbitions for cybernetic concepts, however, and in 7he Human Use of Human Beings he spells out his thoughts on its application to topics as diverse as Maxwell’s Demon, human language, the brain, insect metabolism, the legal system, the role of technological innovation in government, and religion. These broa

e are human ones. But there is no reason to suppose that an AGI created in a society consisting primarily of decent citizens, and raised without what William Blake called “mind-forg’d manacles,” will in general impose such manacles on itself (1.e., become irrational) and/or choose to be an enemy of civilization.