Epstein Secrets

aine Maxwell and Jeffrey Epstein when was under the age of eighteen. 9. Between 1999 and 2002, with the assistance and participation of Maxwell, Epstein sexually abused at numerous locations including his mansions in West Palm Beach, Florida, and in this District. Between 2001 and 2007, with the ass

e after being recruited by Ghislaine Maxwell and Jeffrey Epstein when was under the age of eighteen. 9.

727 --- PAGE BREAK --- Case 1:15-cv-07433-LAP Document 1 Filed 09/21/15 Page 3 of 12 PARTIES 6. Plaintiff is an individual who is a citizen of the State of Colorado. 7. Defendant Maxwell, who is domiciled in the Southern District of New York, is not a citizen of the state of Colorado. FACTUAL ALLEGATIONS 8.

tein's victims. As a consequence, the victims were not told about the NPA. 16. On July 7, 2008, a young woman identified as Jane Doe No. 1, one of Jeffrey Epstein's victims (other than 1, filed a petition to enforce her rights under the Crime Victims' Rights Act ("CVRA"), 18 U.S.C. ¶ 3771, alleging that the G

tein's victims. As a consequence, the victims were not told about the NPA. 16. On July 7, 2008, a young woman identified as Jane Doe No. 1, one of Jeffrey Epstein's victims (other than filed a petition to enforce her rights under the Crime Victims' Rights Act ("CVRA"), 18 U.S.C. ¶ 3771, alleging that the Govern

laine Maxwell and Jeffrey Epstein whe of eighteen. 9. vas under the age Between 1999 and 2002, with the assistance and participation of Maxwell, Epstein sexually abused at numerous locations including his mansions in West Palm Beach, Florida, and in this District. Between 2001 and 2007, with the ass

e after being recruited by Ghislaine Maxwell and Jeffrey Epstein whe of eighteen. 9. vas under the age

his Court. 2 EFTA00676991 Case 1:15-cv-07433 Document 1 Filed 09/21/15 Page 3 of 12 PARTIES. 6. Plaintiff is an individual who is a citizen of the State of Colorado. 7. Defendant Maxwell, who is domiciled in the Southern District of New York, is not a citizen of the state of Colorado. FACTUAL ALLEGATIONS 8.

istrict of Florida (the "Federal Action") more than eight years ago. In the Federal Action, Edwards and Cassell represent certain alleged victims of Jeffrey Epstein, a client of Dershowitz's, who contend that the Government violated their rights under the Crime Victims Rights Act (the "CVRA"). Specifically, the

the Government violated their rights under the CVRA by failing to consult with them before negotiating a non-prosecution agreement (the "NPA") with Epstein, who allegedly subjected them to various sexual crimes when they were minors. On December 30, 2014 — more than eight years after the Federal Action

and Cassell represent certain alleged victims of Jeffrey Epstein, a client of Dershowitz's, who contend t

is true—and that they were in fact true. Pursuant to the stipulated order entered by this Court on March 20, 2015 that appointed a Commissioner in the State of Colorado, Dershowitz served a subpoena for the production of documents and a videotaped deposition on Jane Doe No. 3. See Exhibit G.2. The subpoena seeks, a

and Cassell represent certain alleged victims of Jeffrey Epstein, a client of Dershowitz's, who contend t

istrict of Florida (the "Federal Action") more than eight years ago. In the Federal Action, Edwards and Cassell represent certain alleged victims of Jeffrey Epstein, a client of Dershowitz's, who contend that the Government violated their rights under the Crime Victims Rights Act (the "CVRA"). Specifically, the

the Government violated their rights under the CVRA by failing to consult with them before negotiating a non-prosecution agreement (the "NPA") with Epstein, who allegedly subjected them to various sexual crimes when they were minors. On December 30, 2014 — more than eight years after the Federal Action

founded pleading." Exhibit A, Compl. 17. Pursuant to the stipulated order entered by this Court on March 20, 2015 that appointed a Commissioner in the State of Colorado, Dershowitz served a subpoena for the production of documents and a videotaped deposition on Jane Doe No. 3. See Exhibit G.2 The subpoena seeks, am

, Defendant. X 15-cv-07433-RWS Declaration Of Jeffrey S. Pagliuca In Support Of Defendant's Motion In

pert Testimony and Opinion of Professor Terry Coonan, J.D. I. Jeffrey S. Pagliuca, declare as follows: 1. I am an attorney at law duly licensed in the State of Colorado and admitted to practice in the United States District Court for the Southern District of New York pro hac vice. I am a member of the law firm Hadd

IN WITNESS WHEREOF, the parties hereto have duly executed this Assignment as of the date first set forth above. MWB CORPORATE SERVICES, LLC By: Jeffrey I Owen, Manager "Assignor" STONY POINT I, LLC 2115210 FAA Assignment By: Stony Point Group, Inc. its sole Member 2 "Assignee" SDNY_GM_02758

nt. Governing Lew. This Agreement will be governed by federal law applicable to Lender and, to the extent not preempted by federal law, the laws of the State of Colorado without regard to Its conflicts of law provisions. This Agreement has been accepted by Lender In the State of Colorado. Choice of Venue. If there i