Epstein Secrets

Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Counsel for Ghislaine Maxwell Michael Miller Justin Y.K Chu Michael A. Keough STEPTOE & JOHNSON LLP 1114 Avenue of the Americas New York, NY 10036 Scott J. Link LINK & ROCKENBACH, PA 155

All Defendants) All documents evidencing money paid to at any time. DOCUMENT REQUEST NO. 6 (Directed to All Defendants) All documents relating to the Fashion Institute of Technology ("F.I.T."). 7 EFTA00793331 DOCUMENT REQUEST NO. 7 (Directed to All Defendants) All communications with F.I.T. related in any way to DOCUMENT RE

ue in which to litigate this matter would be in the U.S. Virgin Islands. Dated: July 2017 Respectfully submitted, STEPTOE & JOHNSON, LLP By /s/ Michael Miller Justin Y.K. Chu Attorneys for Defendants JEFFREY EPSTEIN & To: FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. Brad Edwards Attorney

ns of fraud boil down to this: Epstein allegedly "confirmed to Plaintiff that he would use his wealth and influence to have Plaintiff admitted into the Fashion Institute of Technology" ("E") and to advanced her career, but had no intention of doing so. FAC ¶¶ 38, 53, 58-64. This is insufficient to satisfy Rule 9(b). First, the F

lled) (In open court) MS. MCCAWLEY: Sigrid McCawley for plaintiff, along with my co-counsel Paul Cassell. MR. MILLER: Good afternoon, your Honor. Michael Miller and Justin Chu from the law firm of Steptoe & Johnson, and Darren Indyke, who is counsel to Mr. Epstein. We represent Jeffery Epstein and , and ye

again that her sexual compliance would be SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00285645 16 I877DOEC rewarded with admission to the Fashion Institute of Technology or a comparable college, a promise which they knew to be false." 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25