Epstein Secrets

ion in March 2011. Constitutionally protected opinion. The United States Constitution and the New York Constitution renders opinion nonactionable. United Kingdom's Defamation Act of 2013. Mr. Barden prepared the January 2015 statement in compliance with the Defamation Act. To the extent the Act applies in this

half of Ms. Maxwell. No further communication will be provided by her on this matter. 6 EFTA00792761 Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is o not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The origin

ion in March 2011. Constitutionally protected opinion. The United States Constitution and the New York Constitution renders opinion nonactionable. United Kingdom's Defamation Act of 2013. Mr. Barden prepared the January 2015 statement in compliance with the Defamation Act. To the extent the Act applies in this

half of Ms. Maxwell. No further communication will be provided by her on this matter. 6 EFTA00617401 Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is so not a new individual. The allegations made by against Ghislaine Maxwell are untrue. The original allegations a

er with your or Jeffrey Epstein. ANSWER: 11 EFTA00091343 13. Identify your basis for your contention that Plaintiff's claims are barred by the United Kingdom's Defamation Act of 2013. ANSWER: 14. Identify the basis, including all underlying facts, for your contention that statements made by Ms. Maxwell o

rized by you or authorized your agent(s) to make statements on your behalf in January of 2015. ANSWER: 2. Identify any action that you took after Ross Gow issued the January 2015 statement regarding Ms. to the public to retract or remediate the statement, clarify the statement, or otherwise cause a d

endant takes issue with the Indictment's reference to these sex acts as "abuse" because, she asserts, Minor Victim-3 was above the age of consent in the United Kingdom at the time they occurred. The description in the Indictment is factually accurate, however, because Minor Victim- 3 will testify to her subjective

endant also "`participat[ed] in the sexual abuse"' of others. Id. A few days later, the press reported a statement by a spokesman for the defendant, Ross Gow. Among other things, 45 =filed a corrected motion on January 2, 2015. See Doe, No. 08 Civ. 80736, Dkt. No.280. The court later struck the original

endant takes issue with the Indictment's reference to these sex acts as "abuse" because, she asserts, Minor Victim-3 was above the age of consent in the United Kingdom at the time they occurred. The description in the Indictment is factually accurate, however, because Minor Victim- 3 will testify to her subjective

fendant also "`participat[ed] in the sexual abuse" of others. Id. A few days later, the press reported a statement by a spokesman for the defendant, Ross Gow. Among other things, 45 Giuffre filed a corrected motion on January 2, 2015. See Doe, No. 08 Civ. 80736, Dkt. No. 280. The court later struck the o

endant takes issue with the Indictment's reference to these sex acts as "abuse" because, she asserts, Minor Victim-3 was above the age of consent in the United Kingdom at the time they occurred. The description in the Indictment is factually accurate, however, because Minor Victim- 3 will testify to her subjective

fendant also "`participat[ed] in the sexual abuse" of others. Id. A few days later, the press reported a statement by a spokesman for the defendant, Ross Gow. Among other things, 45 Giuffre filed a corrected motion on January 2, 2015. See Doe, No. 08 Civ. 80736, Dkt. No. 280. The court later struck the o

motion takes issue with the Indictment's reference to these sex acts as "abuse" because, the assert, Minor Victim-3 was above the age of consent in the United Kingdom at the time they occurred. The description in the Indictment is factually accurate, however, because Minor Victim-3 subjectively experienced these

to ain (Mailgjuffre alleged that "participat[ed] in the sexual A few days later, the press reported a statement by a spokesman for the defendant, Ross Gow. Among other things, Gow stated that Giuffre's claims were "untrue" and "obvious lies." (15 Civ. 7433 (LAP), Dkt. No. 1 at 6). 45 Giuffre filed a c

endant takes issue with the Indictment's reference to these sex acts as "abuse" because, she asserts, Minor Victim-3 was above the age of consent in the United Kingdom at the time they occurred. The description in the Indictment is factually accurate, however, because Minor Victim- 3 will testify to her subjective

fendant also "`participat[ed] in the sexual abuse" of others. Id. A few days later, the press reported a statement by a spokesman for the defendant, Ross Gow. Among other things, 45 filed a corrected motion on January 2, 2015. See Doe, No. 08 Civ. 80736, Dkt. No. 280. The court later struck the original