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eclare as follows: 1. Iam an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. Iam a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit
Page: HOUSE_OVERSIGHT_014652 →‘We'd do family things, like watch Sex And The City and eat popcorn. ‘A lot of it was very glamorous. | met famous friends of his such as Al Gore and Heidi Klum and Naomi Campbell. He introduced me as his “travelling masseuse.” Some people mistook me for his daughter. ‘When we were in New York or Palm Beach,
Page: HOUSE_OVERSIGHT_014664 →rs, the same standard governs the addition of parties under Rule 21 and Rule 15. See Goston v. Potter, No. 08-cv-478 FJS ATB, 2010 WL 4774238, at *5 (N.D.N.Y. 2010) (citing Bridgeport Music, Inc. v. Universal Music Grp., Inc., 248 F.R.D. 408, 412 (S.D.N.Y. 2008)). 4 GIUFFRE002847 HOUSE_OVERSIGHT_014680
Page: HOUSE_OVERSIGHT_014681 →lorado. 7. Defendant Maxwell, who is domiciled in the Southern District of New York, is not a citizen of the state of Col
fre’s factual assertions as “entirely false” and “entirely untrue.” 32. Maxwell made the same false and defamatory statements as set forth above, in the Southern District of New York and elsewhere in a deliberate effort to maliciously discredit Giuffre and silence her efforts to expose sex crimes committed around the world by Maxw
Page: HOUSE_OVERSIGHT_015536 →conduct, but just tell me what the names of the people are that you remember that you consider to be famous people. V: Ok, there was Naomi Campbell, Heidi Klum, there was Bill Clinton. There was Al (?) Gore, there was a whole bunch of models, I wouldn’t really honestly be able to give their names. There was
Page: HOUSE_OVERSIGHT_015569 →eclare as follows: 1. Iam an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. Iam a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit
Page: HOUSE_OVERSIGHT_014797 →xwell's oth birthelay. In cetween, she took him ta an infernous ‘hookers and pimps’ party sts New vork niertclub hested by the former lingerie model Heicli Klum ina back ates SAM ourfir. SSS ee JAMESON puts HUGE haby bump on display in fevealing JMMpsult during lunch date with Aanee Lise Bitten F From samp
Page: HOUSE_OVERSIGHT_014829 →s sexual trafficking victims in a case pending in the Southern District of Florida, specifically case no. 08-cv-80736- KA
in Aspen, the Picasso painting and $65,000-a-month' in divorce from Antonio Banderas After 19 years together b'I'm happier taking my clothes off!’ Heidi Klum strips to her underwear... but reveals she suffers stage fright on live TV Supermodel is now 42 »'Time to move on’: Ariel Winter hints at split wit
Page: HOUSE_OVERSIGHT_015645 →Entities connected to both Heidi Klum and District Court for the Southern District of New York

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Marc Rich
PERSON
Department of Justice
ORGANIZATIONJane Doe
PERSON
United States
LOCATION
Donald Trump
PERSON
Bill Clinton
PERSON
Bradley Edwards
PERSON
U.S. Virgin Islands
LOCATION
Alan Dershowitz
PERSONFBI
ORGANIZATIONMartin Weinberg
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSON
Virginia Giuffre
PERSON
Upper East Side
LOCATIONJack Goldberger
PERSON
Alexander Acosta
PERSON