Epstein Secrets

status of discovery, Plaintiff respectfully requests that she be allowed to move forward. The sixteen cases currently pending against the Estate of Jeffrey Epstein in the Southern District of New York are all in very different stages of litigation. Two cases have already been stayed by agreement of the parties.

its participants from liability and accountability." (Id., at 18.) The New York Times reports that this lawsuit "seeks to head off an effort by Mr. Epstein's executor, Mr. Indyke, to turn Mr. Epstein's vast wealth into a victim's compensatory fund."' Particularly in light of these recent developments,

District of New York are all in very different stages of litigation. Two cases have already been stayed by agreement of the parties. Doe 1 et a! v. Jeffrey Epstein et at, 19-cv-07675-GBD-DCF (S.D.N.Y.); Doe 17 v. ',dyke et at, 19-cv-09610-PAE-DCF (S.D.N.Y.). One was filed recently, on December 27, 2019. Anasta

een cases currently pending against the Estate of Jeffrey Epstein in the Southern District of New York are

hat this lawsuit "seeks to head off an effort by Mr. Epstein's executor, Mr. Indyke, to turn Mr. Epstein's va

States District Court Southern District of New York Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007 The Honorable Debra Freeman United States District Court Southern District of New York Daniel Patrick Moynihan Courthouse 500 Pearl Street New York, NY 10007 Re: Doe v. I

uly 10.2020.2:06 AN1 • I I mm mod GNsialne Maxwell behind ban as new details emerge Jeffrey Epstein's ex-gw1.0. Wenta. groom and 11 VI • J.66, Epstem's sex aunts by he@ng him Ghislaine Maxwell, a British socialite and longtime companion of disgraced financier Jeffrey Epstein, is facing a reckonin

ficant facts since briefing closed on the first round of review of sealed materials. After many months of relentless negative media coverage of Mr. Epstein and allegations that Ms. Maxwell was involved in his criminal activities, the government secured an indictment against her. On July 2, one day after

his apartments in New York City — near his own townhouse, where he would allegedly rape her the next year. MAIM Feds finally start investigating Jeffrey Epstein's gal pal Ghislaine Maxwell "In 1997, while at Epstein's townhouse on 9 East 71st Street in the City of New York. Epstein asked 17-year-old Doe if sh

TA00075089 ca3FtsVrit5164 Get. PtiftitPtiktivektA8Siig W*40441319 Q. List all the people under the age of 18 that you interacted with at any of Jeffrey's properties? A. I'm not aware of anybody that I interacted with, other than obviously (the plaintiff) who was 17 at this point. (Title 18, Unit

months of relentless negative media coverage of Mr. Epstein and allegations that Ms. Maxwell was involved in

pstein 'co-conspirators' on the same topic as Plaintiff alleges in this case," Maxwell's attorney wrote in a May13 letter to Manhattan federal Judge Debra Freeman seeking to stay discovery in the case. "Denial of a stay, particularly a stay of Ms. Maxwell's deposition, pending outcome of the criminal investiga

y in the Epstein Claims Resolution Program, yet a stay also would permit her the opportunity to do so. She is inexplicably the only of the numerous Epstein plaintiffs in this Court to not agree to such a stay. While Plaintiff's counsel refuses to state whether his client is one of the three accusers in

n and Foreman, r.c Laura A. Menninger 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FR 303.832.2628 August 19, 2020 VIA ECF Hon. Debra Freeman United States Magistrate Judge Daniel Patrick Moynihan United States Courthouse 500 Pearl St. New York, NY 10007-1312 Re: Letter Motion to Sta

an "ongoing" criminal investigation into alleged Jeffrey Epstein co-conspirators and on that plaintiff's s

esting a stay of discovery as to her, based on the U.S. Attorney's Office's public proclamation of an "ongoing" criminal investigation into alleged Jeffrey Epstein co-conspirators and on that plaintiff's stated intent to participate in the Voluntary Claims Resolution Program in the U.S. Virgin Islands. v. Indy

for each of the other pending actions concerning Mr. Epstein and the one other concerning Ms. Maxwell, requir

Claims Resolution Program in the U.S. Virgin Islands (the "Program"), under which the Estate will make compensatory payments to alleged victims of Jeffrey Epstein. Plaintiffs who participate in the Program and accept payment will be required to release all former employees or potential indemnitees of the Esta

or potential indemnitees of the Estate, including Ms. Maxwell, from any and all claims or causes of action that concern acts of sexual abuse by Mr. Epstein. We understand that, if the Program is approved, it may begin making payments as early as August 2020. Hence, Plaintiff's participation in the Prog

make compensatory payments to alleged victims of Jeffrey Epstein. Plaintiffs who participate in the Progr

s of action that concern acts of sexual abuse by Mr. Epstein. We understand that, if the Program is approved,

Case 1:19-cv-10475-LGS-DCF Document 68 Filed 05/13/20 Page 1 of 3 H A D D O N MORGAN FOREMAN May 13, 2020 VIA ECF Hon. Debra Freeman United States Magistrate Judge Daniel Patrick Moynihan United States Courthouse 500 Pearl St. New York, NY 10007-1312 Re: 19-cv- 10475 (LGS-DC

Jeffrey Epstein's Right-Hand Mystery Men THE LAWYER AND THE ACCOUNTANT EFTA00163119 One of the men was described by a source as "Epstein's confidant and aide fo

Jeffrey Epstein's Right-Hand Mystery Men THE LAWYER AND THE ACCOUNTANT EFTA00163119 One of the men was described by a source as "Epstein's confidant and aide for decades." The other was his longtime accountant. Both could soon be questioned. EFTA00163120 Kate Briquelet Senior Rep

ida prosecutors—Epstein paid for "prohibitively expensive in-vitro fertilization cycles," for him and his wife. "Shortly after I began working for Jeffrey, I experienced a personal and unexpected tragedy. After five years of marriage, my wife and I learned that I was infertile and we could not have ch

would like to know to what extent he knew about Mr. Epstein and Ms. Maxwell's criminal enterprise. We would l

even acted on Jeffrey Epstein's behalf to communicate with Plaintiff on several occasions," the lawyer Robert Glassman wrote to U.S. District Judge Debra Freeman, responding to the estate's push to delay the under-oath grilling. Doe also plans to depose Kahn. In an email thread attached to his letter, Glass

Jeffrey Epstein's Right-Hand Mystery Men THE LAWYER AND THE ACCOUNTANT EFTA01654937 One of the men was described by a source as "Epstein's confidant and aide fo

Jeffrey Epstein's Right-Hand Mystery Men THE LAWYER AND THE ACCOUNTANT EFTA01654937 One of the men was described by a source as "Epstein's confidant and aide for decades." The other was his longtime accountant. Both could soon be questioned. EFTA01654938 Kate Briquelet Senior Rep

ida prosecutors—Epstein paid for "prohibitively expensive in-vitro fertilization cycles," for him and his wife. "Shortly after I began working for Jeffrey, I experienced a personal and unexpected tragedy. After five years of marriage, my wife and I learned that I was infertile and we could not have ch

would like to know to what extent he knew about Mr. Epstein and Ms. Maxwell's criminal enterprise. We would l

even acted on Jeffrey Epstein's behalf to communicate with Plaintiff on several occasions," the lawyer Robert Glassman wrote to U.S. District Judge Debra Freeman, responding to the estate's push to delay the under-oath grilling. Doe also plans to depose Kahn. In an email thread attached to his letter, Glass

ein's properties in New York, Florida, and New Mexico, between approximately 1994 and 1997. As the Indictment details, Maxwell played a key role in Epstein's abuse of minors by helping Epstein to identify, groom, and ultimately abuse underage girls. ' While the Government understands that letters from

rom a scheme to sexually abuse underage girls at Jeffrey Epstein's properties in New York, Florida, and Ne

F Document 80 Filed 09/09/20 Page 1 of 4 U.S. Department of Justice United States Attorney Southern District of New York BY EMAIL' The Honorable Debra Freeman United States District Court Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007 The Silvio J. Mol

2015 WL 8207496, at *24 (E.D.N.Y. Dec. 7, 2015). The complaint in this civil action alleges that Maxwell facilitated the sexual abuse of a minor by Jeffrey Epstein in the 1990s. Those allegations will, by definition, touch on matters relating to the pending Indictment. Indeed, based on a review of the civil com

ns Questioning Delay In Epstein Lawsuit. Fox News (5/23, Chakraborty, 27.59M) reports, "Ghislaine Maxwell, the alleged madam of disgraced financier Jeffrey Epstein, won a critical request on Friday to delay questioning in a civil suit filed against her on the grounds that her sworn testimony could incriminate h

let us know whether the claims process is likely to go forward.' Fox News adds, "Though Maxwell faces multiple lawsuits against her for her role in Epstein's alleged nefarious activities, Friday's ruling specifically dealt with a lawsuit filed by Earlier this month, Maxwell's lawyer, Laura Menninger, as

axwell, the alleged madam of disgraced financier Jeffrey Epstein, won a critical request on Friday to dela

riminal case against her in the future. `I'm permitting her not to respond to (written questions) and not to have her deposition,' Magistrate Judge Debra Freeman said during her ruling. `Not forever, but at least long enough to let us know whether the claims process is likely to go forward.' Fox News adds, "T

his apartments in New York City — near his own townhouse, where he would allegedly rape her the next year. MAIM Feds finally start investigating Jeffrey Epstein's gal pal Ghislaine Maxwell "In 1997, while at Epstein's townhouse on 9 East 71st Street in the City of New York. Epstein asked 17-year-old Doe if sh

known victim" says she was sexually abused by the now-dead pedophile — who called himself her "Godfather" — when she was 13 years old. Jane Doe met Epstein and his friend, Ghislaine Maxwell. in the summer of 1994 at Michigan's Interlochen Arts Camp, where she was In voice training, according to newly fi

s, I hired all sorts of people." "A very small part of my job," she added, "was from time to time to find adult professional massage therapists for Jeffrey." She denied, under oath, that she had ever hired underage girls to work for Epstein, assertions that are now the subject of perjury charges. "As

pstein 'co-conspirators' on the same topic as Plaintiff alleges in this case," Maxwell's attorney wrote in a May13 letter to Manhattan federal Judge Debra Freeman seeking to stay discovery in the case. "Denial of a stay, particularly a stay of Ms. Maxwell's deposition, pending outcome of the criminal investiga

a stay will "harm plaintiff's interests," she fails to explain why. Ipse dixit aside, Plaintiff correctly explains that she can participate in the Epstein claims program while simultaneously pursuing this civil action and (apparently) advancing her interests through the Criminal Case. But she does not

Maxwell, and the truth, from participating. With Mr. Epstein dead and Ms. Maxwell, literally, handcuffed, the

O East 10th Avenue Denver. Colorado 80203 rti 303.831.7364 rx 303.832.2628 www.hmflaw.com Imenningerehmflaw.com September 4, 2020 VIA ECF Hon. Debra Freeman United States Magistrate Judge Daniel Patrick Moynihan United States Courthouse 500 Pearl St. New York, NY 10007-1312 Re: Reply in Support of