Epstein Secrets

Date Pledged Indebtedness or Assigned 10. For each account receivable, or note receivable you had immediately prior to the commencement of this Action, at the beginning of each calendar year thereafter during the period in question and as of the present date, set forth the name, address and teleph

, without limitation, in emails, texts or other digital or electronic format) between Jack Scarola, Searcy Denney Scarola Barnhart & Shipley PA, or Boies Schiller Flexner LLP, on the one hand and any and all attorneys, investigators, paraprofessionals, and other contractors or individuals (including, without limitation,

rogatories contractors or individuals (including, wi ' • services provided to or for the benefit of you, Jane Doe andk in connection with this Action, or any other matters pertaining to or involving Jeffrey Epstein. Include in your response the format in which any such promises, contracts, agreem

g, without limitation, in emails, texts or other digital or electronic format) between Jack Scarola, Searcy Denney Scarola Barnhart & Shipley PA, or Boies Schiller Flexner LLP, and/or any and all attorneys, investigators, paraprofessionals, and other contractors or individuals (including, without limitation, witnesses) fo

he Court should ignore these baseless allegations. M— the administrator of the Epstein Victims' Compensation Program, which ended long before this Action was filed and is unrelated to the Settlement—is not a Claims Administrator in this case, and Jane Doe 7 fails to 8 EFTA00145654 Case 1:22-cv-100

es and expenses. Dated: November 2, 2023 Respectfully submitted, /s/ David Boies David Boies Andrew Villacastin Sabina Mariella Alexander Law Boies Schiller Flexner LLP 55 Hudson Yards New York, NY Telephone: (212) 446-2300 Fax: (212) 446-2350 Email: [email protected] Email: [email protected] Email: smar

(including, without limitation, witnesses) for services provided to or for the benefit of you, LM, EW, Jane Doe and/or M) in connection with this Action, or any other matters pertaining to or involving Jeffrey Epstein. Include in your response the format in which any such promises, contracts, agreem

g, without limitation, in emails, texts or other digital or electronic format) between Jack Scarola, Searcy Denney Scarola Barnhart & Shipley PA, or Boies Schiller Flexner LLP, and/or any and all attorneys, investigators, paraprofessionals, and other contractors or individuals (including, without limitation, witnesses) fo

islaine Maxwell submits this reply in support of her Motion to suppress all evidence the government obtained from a grand jury subpoena it issued to Boies Schiller Flexner LLP and to dismiss Counts Five and Six, which are the fruits of that unlawful subpoena. Introduction and Summary of the Argument If the government mea

or Boies Schiller had anything to do with the Government's decision to convene a grand jury to look into the matters that were the subject of the Action. On the contrary—the Government has advised the Court that it contacted Boies Schiller as part of its search for parties who might have been victim

EFTA00029081 --- PAGE BREAK --- Ghislaine Maxwell moves to suppress all evidence the government obtained from a grand jury subpoena it issued to Boies Schiller Flexner LLP and to dismiss Counts Five and Six, which are the fruits of that unlawful subpoena. INTRODUCTION AND SUMMARY OF THE ARGUMENT Counts Five and Six a

or Boies Schiller had anything to do with the Government's decision to convene a grand jury to look into the matters that were the subject of the Action. On the contrary—the Government has advised the Court that it contacted Boies Schiller as part of its search for parties who might have been victim