Epstein Secrets

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

433-RWS Document 539-1 Filed 01/06/17 Page 4 of 9 6/14/2016 Manhattan. The photograph that appeared last weekend shows the prince strolling through Central Park with 58-year-old Epstein. Andrew was said to have spent four days at his New York mansion in December, when he was joined by other distinguished gues

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

s sexual trafficking victims in a case pending in the Southern District of Florida, specifically case no. 08-cv-80736- KA

avorting with Ghislaine at a Halloween fetishthemed party in Manhattan. The photograph that appeared last weekend shows the prince strolling through Central Park with 58-year-old Epstein. Andrew was said to have spent four days at his New York mansion in December, when he was joined by other distinguished gues

a complaint filed in the U.S. District Court for the Southern District of Florida, an alleged victim said that Epstein,

Jr., the Manhattan D.A., allow a Level 3 sex offender (the most dangerous kind) to reside -- even for ten minutes -- in a house that is right next to Central Park and a school? Isn't that unlawful given the housing guidelines for sex offenders? According to the NYPost, Epstein's Level 3 designation means that h