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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
d, the media obtained copies of the motion. At issue is a January 2, 2015, statement prepared by Ms. Maxwell's British solicitor Philip Barden. Mr. Barden sent the statement to Ms. Maxwell for approval and, following approval, caused Mr. Gow to send (via email) the statement to six to thirty members of
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
d, the media obtained copies of the motion. At issue is a January 2, 2015, statement prepared by Ms. Maxwell's British solicitor Philip Barden. Mr. Barden sent the statement to Ms. Maxwell for approval and, following approval, caused Mr. Gow to send (via email) the statement to six to thirty members of
18 view as sort of indicia of she should have known about what's 19 in these police reports, and they first of all say -- we get 20 back to this Dershowitz joint defense agreement issue, which I 21 touched on yesterday, but you're going to hear it again today, 22 so I think it's worth mentioning agai
nswer the question if it's not privileged." That's the 9 testimony that they say supports their assertion of this joint 10 defense agreement with Alan Dershowitz. 11 But there's more, your Honor. Mr. Edwards -- again, 12 who is a party in this deposition and not a lawyer -- chimes in 13 to the special ma
sertion of this joint 10 defense agreement with Alan Dershowitz. 11 But there's more, your Honor. Mr
fered for the truth of 5 the matter asserted, we want to offer it to show Ms. Maxwell's 6 state of mind when she issued her statement through Mr. Barden 7 and Mr. Gow. So the huge problem with that, your Honor, which 8 we've already dealt with, is, Ms. Maxwell has no knowledge of 9 what's in the
what they view as sort of indicia of she should have known about what's in these police reports, and they first of all say -- we get back to this Dershowitz joint defense agreement issue, which I touched on yesterday, but you're going to hear it again today, so I think it's worth mentioning again. And h
nswer the question if it's not privileged." That's the 9 testimony that they say supports their assertion of this joint 10 defense agreement with Alan Dershowitz. 11 But there's more, your Honor. Mr. Edwards -- again, 12 who is a party in this deposition and not a lawyer -- chimes in 13 to the special ma
sertion of this joint 10 defense agreement with Alan Dershowitz. 11 But there's more, your Honor. Mr
fered for the truth of 5 the matter asserted, we want to offer it to show Ms. Maxwell's 6 state of mind when she issued her statement through Mr. Barden 7 and Mr. Gow. So the huge problem with that, your Honor, which 8 we've already dealt with, is, Ms. Maxwell has no knowledge of 9 what's in the
what they view as sort of indicia of she should have known about what's in these police reports, and they first of all say -- we get back to this Dershowitz joint defense agreement issue, which I touched on yesterday, but you're going to hear it again today, so I think it's worth mentioning again. And her
py to answer the question if it's not privileged." That's the testimony that they say supports their assertion of this joint defense agreement with Alan Dershowitz. But there's more, your Honor. Mr. Edwards -- again, who is a party in this deposition and not a lawyer -- chimes in to the special master and Mr.
r assertion of this joint defense agreement with Alan Dershowitz. But there's more, your Honor. Mr. Ed
ing offered for the truth of the matter asserted, we want to offer it to show Ms. Maxwell's state of mind when she issued her statement through Mr. Barden and Mr. Gow. So the huge problem with that, your Honor, which Ww ' ve already dealt with, is, Ms. Maxwell has no knowledge of what's in these poli
reading of that document, the press release by Barden and Gow, is that she's talking about the allegations against her, Maxwell, and she includes Dershowitz, and that's essentially it. I mean, she's not parsing through the 102 pleading and saying, you know, this is wrong and that is wrong. And the funda
hey have the burden of proving that what Ms. Maxwell said was false. That's what is at issue. We have to look at Ms. Maxwell's statement issued by Barden and Gow and then go backwards from there. And the burden on the plaintiff is proving falsity of that statement. It is not the situation where -- wh
that 21 document, the press release by Barden and Gow, is that she's 22 talking about the allegations against her, Maxwell, and she 23 includes Dershowitz, and that's essentially it. I mean, she's 24 not parsing through the 102 pleading and saying, you know, this 25 is wrong and that is wrong. And t
the burden of proving that what Ms. Maxwell said was false. 16 That's what is at issue. We have to look at Ms. Maxwell's 17 statement issued by Barden and Gow and then go backwards from 18 there. And the burden on the plaintiff is proving falsity of 19 that statement. It is not the situation whe
Entities connected to both Alan Dershowitz and Barden

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Lesley Groff
PERSON
United States
LOCATION
George W. Bush
PERSON
Paul Cassell
PERSONDarren Indyke
PERSON
Kenneth Marra
PERSONMartin Weinberg
PERSONMaria Farmer
PERSONSouthern District
LOCATION
Virginia Giuffre
PERSONthe Southern District
LOCATION
Alexander Acosta
PERSONScott Rothstein
PERSON
Alfredo Rodriguez
PERSON
Jean-Luc Brunel
PERSON