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legations 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 well-known Prime Minister, and other world
light on the false accusations directed at Ms. Maxwell. In response to Plaintiff's published claims, Ms. Maxwell (like Prince Andrew and Professor Dershowitz), issued general denials to the allegations. Those two denials form the basis of this defamation action: Plaintiff claims it defamatory for Ms. Maxw
shed claims, Ms. Maxwell (like Prince Andrew and Professor Dershowitz), issued general denials to the allegations. Thos
such as Prince Andrew and Harvard Law Professor Alan Dershowitz, as well as un-named "numerous Americ
rivilege and therefore is not actionable. Further, general denials such as the January 3 Statement are not actionable as defamatory statements. See McNamee v. Clemens, 762 F.Supp.2d 584, 601 (E.D.N.Y. 2011) ("general denials of accusations aren't actionable"); Independent Living Aids, Inc. v. Mau-Aids,
e story is re told [sic] it changes with new salacious details about public figures and world leaders and now it is alleged by Ms Roberts [sic] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies. Ms Roberts claims are obvious lies and should be treated as such and not pub
ue New York, NY 10022 7. (live) c/o Justine Harris Sher Tremonte 80 Broad Street, 13th Fl. New York, NY 10004 8. MI (live) New York, NY 9. Dershowitz (live) c/o Richard A. Simpson, Esq. WILEY REIN, LLP 1776 K Street NW Washington, D.C. 20006 14 EFTA00792769 10. Anthony DiVirgilio (live) In
leaders and now it is alleged by Ms. Roberts that Alan Dershowitz is involved and having sexual relatio
nce or actual malice, depending on the plaintiff's status; (4) falsity; (5) special damages or per se libel." February 27, 2016 Order at 6. See also McNamee v. Clemens, 762 F. Supp. 2d 584 (E.D. N.Y. 2011); Dillon v. City of New York, 261 A.D.2d 34 (1999). Ms. alleged that Defendant was involved with
time the story is re told [sic] it changes with new salacious details about public figures and world leaders and now it is alleged by Ms [sic] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies. Ms claims are obvious lies and should be treated as such and not publicised
nsbury Square 5. Richard Barnett (live) 6. Custodian of Records (live) The Mar-a-Lago Club, Inc. 725 Fifth Avenue New York, NY 10022 7. 8. 9. Dershowitz (live) do Richard A. Simpson, Esq. WILEY REIN, LLP 1776 K Street NW Washington, D.C. 20006 14 EFTA00617409 10. Anthony DiVirgilio (live) Inv
world leaders and now it is alleged by Ms. that Alan Dershowitz is involved and having sexual relatio
nce or actual malice, depending on the plaintiff's status; (4) falsity; (5) special damages or per se libel." February 27, 2016 Order at 6. See also McNamee v. Clemens, 762 F. Supp. 2d 584 (E.D. N.Y. 2011); Dillon v. City of New York, 261 A.D.2d 34 (1999). Ms. alleged that Defendant was involved with
Entities connected to both Alan Dershowitz and McNamee

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
George W. Bush
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSONMaria Farmer
PERSONSouthern District
LOCATION
Virginia Giuffre
PERSON
New York
LOCATION
Alfredo Rodriguez
PERSON
Jean-Luc Brunel
PERSON
Wilbur Ross
PERSON
Vicky Ward
PERSON
David Boies
PERSON
David Rodgers
PERSONSigrid McCawley
PERSONFISTOS & LEHRMAN
ORGANIZATION