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principle? Does your argument mean that Professor Dershowitz can go on TV seven days a week, 20 channels a day forever and say the same things? Mr. Cooper: Yes, your Honor. (Tr. 4:23-5:2, Sept. 24, 2019) a a * The Court: So that is essentially if you put it on the intemet you're immune. Mr. Cooper: Y
ge at all." (Del Dismiss Rep. at 10). Whatever he means by this formulation, it does not trump the New York Court of . The Court agrees with Judge Sweet's holding in v. Maxwell that either constitutional malice or law malice can defeat the self-defense privilege, Maxwell, 165 F. Supp. 3d at 155, an
v. Steinberg, 764 N.Y.S.2d 236 (App. Div. 2003)); Cooper v. Sony Records Int 'I,No. 00 Civ. 233 (RMB), 20
P. 9(b) and 12(b)(6). I. PRELIMINARY STATEMENT: MULTIPLE SDNY JUDGES WARNED THE PERSON DRIVING THIS ACTION AGAINST SUCH FRIVOLOUS LAWSUITS Judges Sweet, Berman and Castel warned Steven Hoffenberg ("Hoffenberg"), whom Plaintiffs identify as the "Non-Party Affiant" (Compl. 15) and whose affidavit for
.9kftneDiAgrAeAFIV/P4tEheif6 V- ga ef41th 13 2. Cooper & Kirk's Possession of the Maxwell Materials Bef
th 13 The Maxwell Protective Order, despite the angst it is now causing, is unremarkable in form and function. Like many protective orders, Judge Sweet entered the Maxwell Protective Order in 2016 to "protect the discovery and dissemination of confidential information or information that will impro
orneys after learning that her successor counsel, Cooper & Kirk, had received from her former counsel, Bo
8. In part, Ms. Maxwell needed information concerning any such investigation to assess "the impact on any 5th Amendment privilege." Id. at 8. Judge Sweet denied that motion. The day before Ms. Maxwell's deposition, the Court ordered that "[a]ny materials that the plaintiff has with respect to any cri
ed" to learn that plaintiff's successor counsel, Cooper & Kirk, had received from plaintiff's former coun
In part, Ms. Maxwell needed information concerning any such investigation to assess "the impact on any 5th Amendment privilege." IS at 2, 4-5. Judge Sweet denied that motion. The day before Ms. Maxwell's deposition, the Court ordered that "[a]ny materials that the plaintiff has with respect to any cri
ed" to learn that plaintiff's successor counsel, Cooper & Kirk, had received from plaintiff's former coun
n part, Ms. Maxwell needed information concerning any such investigation to assess "the impact on any 5th Amendment privilege." Id. at 2, 4-5. Judge Sweet denied that motion. The day before Ms. Maxwell's deposition, the Court ordered that "[a]ny materials that the plaintiff has with respect to any cri
to the Protective Order. Doc.1071 at 4. The Court rejected Cooper & Kirk's suggestion that it properly was a recipient of the material: [W]hatever Cooper & Kirk's intentions in requesting and obtaining the Maxwell materials from Boies Schiller, the Maxwell Protective Order explicitly provides that (1
Page: EFTA00021863 →n part, Ms. Maxwell needed information concerning any such investigation to assess "the impact on any 5th Amendment privilege." ki. at 2, 4-5. Judge Sweet denied that motion. The day before Ms. Maxwell's deposition, the Court ordered that "[a]ny materials that the plaintiff has with respect to any cri
Page: EFTA00021868 →Entities connected to both Bradley Cooper and Sweet

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Lesley Groff
PERSONLeon Black
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Julie K. Brown
PERSON
Alan Dershowitz
PERSON
Marc Rich
PERSON
Prince Charles
PERSON
John F. Kennedy
PERSON
Virginia Giuffre
PERSON
United States
LOCATION
Woody Allen
PERSON
Bradley Edwards
PERSON
Eric Trump
PERSON
Department of Justice
ORGANIZATION
Scarlett Johansson
PERSON
Stephen Hawking
PERSON