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aintiff's spurious claims. Plaintiff's allegations of sexual abuse extend beyond just Ms. Maxwell and encompass many notable public figures, such as Prince Andrew and Harvard Law Professor Alan Dershowitz, as well as un-named "numerous American politicians, powerful business executives, foreign presidents, a w
pass many notable public figures, such as Prince Andrew and Harvard Law Professor Alan Dershowitz, as wel
918) 8 EFTA00595585 Case 1:15-cv-07433-RWS Document 15 Filed 12/01/15 Page 4 of 29 Frechtman v. Gutterman, 979 N.Y.S.2d 58 (1st Dep't 2014) 14 Front, Inc. v. Khalil, 24 N.Y.3d 713, 720 (2015) 13 Fuji Photo Film U.S.A., Inc. v. McNulty, 669 F.Supp.2d 405 (S.D.N.Y. 2009) 8 Gertz v. Robert Welch, Inc.,
University of Uta • T, for Plaintiff-Appellee Andrew G. Celli Jr. (David A. Lebowitz, on the brief),
hat document additional credibility, in fact, allegations appearing in such documents might be less credible than those published elsewhere.J9 46 Front, Inc. V. Khalil, 24 N.Y.3d 713, 718, 4 N.Y.S.3d 581, 28 N.E.3d 15 (2015); see also Kelly v. Albarino, 485 F.3d 664, 666 (2d Cir. 2007) (adopting the rea
UT, for Plaintiff-Appellee Virginia L. Giuffre. ANDREW G. CELLI JR. (David A. Lebowitz, on the brief),
d that document additional credibility, in fact, allegations appearing in such documents might be less credible than those published elsewhere" 46 Front, Inc. v. Khalil, 24 N.Y.3d 713, 718 (2015); see also Kelly v. Albarino, 485 F.3d 664, 666 (2d Cir. 2007) (adopting the reasoning of the District Court exp
Entities connected to both Prince Andrew and Front, Inc.

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSONthe Southern District
LOCATION
Virginia Giuffre
PERSON
Julie K. Brown
PERSON
New York
LOCATION
Denver
LOCATION
Kenneth Marra
PERSONJane Doe
PERSON
Alfredo Rodriguez
PERSON
Paul Cassell
PERSONLaura Menninger
PERSON
David Boies
PERSON
Robert Mueller
PERSONSigrid McCawley
PERSON
Southern District of New York
ORGANIZATION
the United States District Court
ORGANIZATION
Cynthia Nixon
PERSON