This is a notice of motion filed by Virginia Giuffre's legal team seeking permission to amend her defamation complaint against Alan Dershowitz in their 2019 lawsuit.
Filed on December 20, 2019, this court document represents Cooper & Kirk PLLC's motion for leave to file an amended complaint in Giuffre v. Dershowitz. Charles Cooper had recently taken over as Giuffre's attorney after her previous counsel David Boies was disqualified from the case. The motion came roughly eight months after Giuffre filed her original defamation lawsuit against Dershowitz, who had publicly called her a 'liar' after she accused him of sexual abuse in connection with Jeffrey Epstein.
Case 1:19-cv-03377-LAP Document 99 Filed 12/20/19 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. ALAN DERSHOWITZ, Defendant. ALAN DERSHOWITZ, Counterclaim Plaintiff, v. Counterclaim Defendant. Civil Action No. I :19-cv-3377 (LAP) Oral Argument Requested NOTICE OF MOTION FOR LEAVE TO FILE AN AMENDED COMPLAINT PLEASE TAKE NOTICE that upon the Declaration of Haley N. Proctor, dated December 20, 2019, together with the exhibits annexed thereto, and the accompanying memorandum of law, the undersigned will move this Court, before the Honorable Loretta A. Preska, United States District Judge for the Southern District of New York, at the United States Courthouse, 500 Pearl Street, New York, New York 10003, at a date and time to be determined by the Court, for an order under Rule 15(a) granting Plaintiff leave to file an amended complaint. PLEASE TAKE FURTHER NOTICE that any response or objection to the motion should be made on or before January 17, 2020, in accordance with the Stipulation and Order dated EFTA00027034
Case 1:19-cv-03377-LAP Document 99 Filed 12/20/19 Page 2 of 3 November 26, 2019, Doc. No. 95. Any reply should be filed on or before January 24, 2020, in accordance with Local Rule 6.1(b). Dated: December 20, 2019 /s/ Charles J. Cooper Charles J. Cooper* Michael W. Kirk* Nicole J. Moss* Haley N. Proctor* COOPER & KIRK PLLC 1523 New Hampshire Ave. NW Washington, DC 74008 (202) 220-9600 *Admitted PHV Attorney for Plaintiff 2 EFTA00027035
Case 1:19-cv-03377-LAP Document 99 Filed 12/20/19 Page 3 of 3 CERTIFICATE OF SERVICE I hereby certify that on December 20, 2019, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system, and I hereby certify that the foregoing was served upon all counsel of record using the CM/ECF system. Is/ Charles J. Cooper Charles J. Cooper* COOPER & KIRK PLLC 1523 New Hampshire Ave. NW Washington, DC 74008 (202) 220-9600 *Admitted PHV Attorney for Plaintiff 3 EFTA00027036