Epstein Secrets

r, "An Appeal to Lillian Hellman and Mary McCarthy," 5/11/80 New York Times 2 Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) 9 Rules Fed. R. Civ. P. 1 12 Constitutional Provisions U.S. CONST. am

ing a time- honored if unfortunate litigation tactic, her lawyers at Boies Schiller therefore sought to turn the lawsuit into a proxy prosecution of Epstein. Not surprisingly, discovery in the case was bitter, hard-fought, and wide-ranging. It spanned more than a year and included large document product

replied, "I don't know what you're talking about." And when asked to "[I]ist all the people under the age of 18 that you interacted with at any of Jeffrey's properties," Maxwell responded, "I'm not aware of anybody that I interacted with, other than obviously I who was 17 at this point." Count Five o

ony when she testified during her July 2016 deposition that: (1) she could not recall whether sex toys or devices were used in sexual activities at Epstein's Palm Beach house; (2) she did not know whether Epstein possessed sex toys or devices used in sexual activities; (3) she wasn't aware that Epstein w

1998) 16 United States v. Cortina, 630 F.3d 1207 (7th Cir. 1980) 16 United States v. Lambus, 897 F.3d 368 (2d Cir. 2018) 16 United States v. Paredes-Cordova, No. S I 03 CR. 987DAB, 2009 WL 1585776 (S.D.N.Y. June 8, 2009) 18 United States v. Rajaratnam, 719 F.3d 139 (2d Ck. 2013) 18 United States v.

ir. 1996) 2 Young v. United States, 481 U.S. 787 (1987) 24 Other Authorities Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) 11 U.S. Dept. of Justice, JUSTICE MANUAL, JM § 9-11.151 15 Rules Fed.

al abuse and trafficking by Jeffrey Epstein and Maxwell. Ex. J, pp 1-3. • At the meeting, attorneys told AUSA the following: o That Maxwell was Epstein's "head recruiter" of underage victims. Id. at 2. o That =vas underage when she was brought to New York "for training by Maxwell and Epstein [in]

OLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

. 2008) 22 United States v. Lambus, 897 F.3d 368 (2d Cir. 2018) 23, 25 United States v. Ming He, 94 F.3d 782 (2d Cir. 1996) 20 United States v. Paredes-Cordova, No. SI 03 CR. 987DAB, 2009 WL 1585776 (S.D.N.Y. June 8, 2009) 25 ii EFTA00077573 United States v. Payner, 447 U.S. 727 (1980) 20 United Stat

OLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

h Cir. 1996) 2 Young v. United States, 481 U.S. 787 (1987) 24 Other Authorities Stephen Rex M, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) 11 U.S. Dept. of Justice, JUSTICE MANUAL, JM § 9-11.151 15 Rules Fed.

al abuse and trafficking by Jeffrey Epstein and Maxwell. Ex. J, pp 1-3. • At the meeting, attorneys told AUSA the following: o That Maxwell was Epstein's "head recruiter" of underage victims. Id. at 2. o That was underage when she was brought to New York "for training by Maxwell and Epstein [in] h

OLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

r. 2008) 22 United States v. Lambus, 897 F.3d 368 (2d Cir. 2018) 23, 25 United States v. Ming He, 94 F.3d 782 (2d Or. 1996) 20 United States v. Paredes-Cordova, No. SI 03 CR. 987DAB, 2009 WL 1585776 June 8, 2009) 25 ii EFTA00029102 --- PAGE BREAK --- United States v. Payner, 447 U.S. 727 (1980) 20 U

ir. 1996) 2 Young v. United States, 481 U.S. 787 (1987) 24 Other Authorities Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) 11 U.S. Dept. of Justice, JUSTICE MANUAL, JM § 9-11.151 15 Rules Fed.