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

while he is also said to be close to Saif Al-Islam Gaddafi, son of the beleaguered Libyan president, and may have had a role in the early release of Lockerbie bomber Abdelbaset Al Megrahi. But it is Andrew's friendship with Epstein, whom H he has known since at least 2000, and with While on the streets, |

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

while he is also said to be close to Saif Al-Islam Gaddafi, son of the beleaguered Libyan president, and may have had a role in the early release of Lockerbie bomber Abdelbaset Al Megrahi. While on the streets, | slept with men for money. | was a paedophile's dream But it is Andrew's friendship with Epste

(S.D.N.Y. 2005) has been a party to lawsuits in the South- ern District of New York, both as a plain- tiff and defendant.

t mat- ter and personal jurisdiction in a case aris- HOUSE_OVERSIGHT_017872 --- PAGE BREAK --- 808 ing from the bombing of Pan Am Flight 103 over Lockerbie, Scotland. The court found it had subject matter jurisdiction over defendant Libya, a designated state sponsor of terror, pursuant to § 1605(a)(7) of