Epstein Secrets

of emails with communications involving various combinations of Brett Jaffe, Esq. ("Jaffe"), Mark Cohen, Esq. ("Cohen"), Philip Barden ("Barden"), Ross Gow ("Gown), Brian Basham ("Basham"), and The facts that follow summarize Defendant's assertions regarding her relationship to each of these individu

3, 2014) (internal quotation marks omitted)). Moreover, at least one New York court has found that British privilege law is "apparently similar" to New York's. Aetna Cas. & Sur. Co. v. Certain Underwriters at Lloyd's London, 4 "Where there is no attorney involved in the communication ..., there can be no

uffre v. Maxwell, No. 15 CIV. 7433 (RWS), 2016 WL 831949, at *2 n.2 (S.D.N.Y. Feb. 29, 2016) ("Because New York has the most significant interest, New York law applies."). The potential litigation for which Defendant sought Barden's advice never came to frOition and no • pending issues in or relating

.Sent from my iPhone On Jun 9, 2011, at 1:21 PM, CiMAX < Forwarded Message From: Reply-To: c Date: Thu, 9 Jun 2011 12:32:23 -0400 To: G G <->, Ross Gow Subject: Re: Vanity Fair Good to go. Sent from my BlackBerry" wireless device > wrote: From: GMAX < Date: Thu, 09 Jun 2011 11:19:51 -0400 To:

ited her as Epstein's "sex slave" when she was 15 years old and arranged for her to see Andrew three times—at Jeffrey Epstein's homes in London and New York and on his private Caribbean island, Little Saint James—where, Virginia said, she'd been "sexually exploited by Epstein's adult male peers, includi

s .Sent from my iPhone On Jun 8, 2011, at 3:42 PM, GMAX <[email protected]> wrote: MY PROPOSED ANS IN CAPS..PLSE COMMENT Forwarded Message From: Ross Gow Date: Tue, 7 Jun 2011 13:49:02 -0400 To: G G < maxl ellmax.com <mailto: maxi ellmax.com» Cc: Brian Basham Subject: Vanity Fair Dear Ghislaine K

ited her as Epstein's "sex slave" when she was 15 years old and arranged for her to see Andrew three times—at Jeffrey Epstein's homes in London and New York and on his private Caribbean island, Little Saint James—where, Virginia said, she'd been "sexually exploited by Epstein's adult male peers, includi

0 PM Subject: FW: Vanity Fair J [email protected]] Title: FW: Vanity Fair MY PROPOSED ANS IN CAPS..PLSE COMMENT Forwarded Message From: Ross Gow Date: Tue, 7 Jun 2011 13:49:02 -0400 To:GG< Cc: Brian Basham Subject: Vanity Fair Dear Ghislaine Klein's questions follow, below. If we are to

ited her as Epstein's "sex slave" when she was 15 years old and arranged for her to see Andrew three times—at Jeffrey Epstein's homes in London and New York and on his private Caribbean island, Little Saint James—where, Virginia said, she'd been "sexually exploited by Epstein's adult male peers, includi

rlier statement and to whom, when or where it was made.' It alleges statements made "in the Southern District and elsewhere" by Ms. Maxwell's agent, Ross Gow, (Comp!. 11 29, 30, 32), but attaches a 2011 statement attributed to Mr. Gow in London. McCawley Decl., Ex. 2. Because the Complaint lacks allegati

(primarily N.Y. state) cases in which the plaintiffs, unlike herself, properly alleged facts which could serve to defeat a qualified privilege. As New York's highest court found: While there are numerous cases in the books in which it is said that as to privileged communications the good faith of the def

to ain (Mailgjuffre alleged that "participat[ed] in the sexual A few days later, the press reported a statement by a spokesman for the defendant, Ross Gow. Among other things, Gow stated that Giuffre's claims were "untrue" and "obvious lies." (15 Civ. 7433 (LAP), Dkt. No. 1 at 6). 45 Giuffre filed a c

rder to be overcome by a showing of improvidence in the grant of the order, extraordinary circumstances or compelling need."); Palmieri v. State of N. Y., 779 F.2d 861, 862 (2d Cir. 1985) (holding that "absent an express finding by the district court of improvidence in the magistrate's initial grant

nninger in Support of Defendant’s Motion For Summary Judgment I, Laura A. Menninger, declare 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 & For

ilure to carry out the most elementary investigation or any real due diligence. Iam now taking action to clear my name," she said. Media contact: Ross Gow Acuity Reputation Tel: +44-203-008-7790 Mob: +44-7778-755-251 Email: [email protected] Media contact: Ross Gow, Acuity Reputation, Tel: