Case 1:15-cv-07433-LAP Document 30 Filed 01/25/16 Page 1 of 3 United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAIINTIFF RESPONSE TO DEFENDANT'S NOTICE OF SUPPLEMENTAL AUTHORITY In response to Defendant's Notice of Supplemental Authority [D.E. # 29], Plaintiff by and through her undersigned counsel, respectfully states as follows: As recounted by Defendant's Notice of Supplemental Authority, the Court found that Cosby's statements were not defamatory because they did not "lead to an inference that Plaintiff is a 'liar and an extortionist!" In vivid contrast, Maxwell called assertions of sexual abuse "obvious lies." It is axiomatic that a person telling "obvious lies" is a liar, and, therefore, the reasoning employed by the.court is inapplicable to the statements made by Maxwell. Dated January 25, 2015 Respectfully Submitted, BOLES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 1 EFTA02779091