Epstein Secrets

limit, yet her proposed depositions are not calculated to lead to admissible evidence in this case. By way of example, Plaintiff identifies ), and Jeffrey Epstein as alleged "co-conspirators" with each other. She requests the depositions of each. Plaintiff anticipates each will invoke the Fifth Amendment — in

harassing questions Plaintiff posed to her concerning her adult, consensual sexual activities. In other words, depositions of Marcincova, Kellen and Epstein would serve Plaintiff's goal to make a convoluted legal argument, not to actually seek discoverable information. In light of this, the "burden or e

UMPTIVE TEN DEPOSITION LIMIT Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. E

and (identified as assistants to Ms. Maxwell or Mr. Epstein). The information Plaintiff claims each of the wi

parties' resources, the importance of the issues at stake in the action, and the importance of the discovery in resolving the issues." Atkinson v. Goord, No. 01 CIV. 0761 LAKHBP, 2009 WL 890682, at *1 (S.D.N.Y. Apr. 2, 2009); Fed. It Civ. P. 26(b)(1). If Plaintiff chooses to use her depositions in th

le income from inheritances. (Def. Ex. O at 5). This is significant, given that the Government has produced to the defendant in discovery a copy of Jeffrey Epstein's will, which includes a $10 million cash grant to the defendant. The financial report further shows that the defendant apparently spent the last five

1994 and 1997. The defendant played a critical role in the scheme by helping to identify, entice, and groom minor girls to engage in sex acts with Epstein. The defendant's presence as an adult woman normalized Epstein's abusive behavior, and she even took part in at least some acts of sexual abuse. Tog

ng the sexual abuse of multiple minor victims by Jeffrey Epstein between approximately 1994 and 1997. The

when denying bail. "A motion for reconsideration may not be used ... as a vehicle for relitigating issues already decided by the Court." Jackson v. Goord, 664 F. Supp. 2d 307, 313 (S.D.N.Y. 2009) (internal quotation marks omitted). The Court already considered and rejected the defendant's efforts to

10) 15 United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009) 27 United States v. English, 629 F.3d 311 (2d Cir. 2011) 7 United States v. Epstein, 155 F. Supp. 2d 323 (E.D. Pa. 2001) 28 United States v. Epstein, 425 F. Supp. 3d 306 (S.D.N.Y. 2019) 15, 29 United States v. Esposito, 309 F. Su

le income from inheritances. (Def. Ex. O at 5). This is significant, given that the Government has produced to the defendant in discovery a copy of Jeffrey Epstein's will, which includes a $10 million cash grant to the defendant. The financial report further shows that the defendant apparently spent the last five

ng the sexual abuse of multiple minor victims by Jeffrey Epstein between approximately 1994 and 1997. The

hen denying bail. "A motion for reconsideration may not be used . . . as a vehicle for relitigating issues already decided by the Court." Jackson v. Goord, 664 F. Supp. 2d 307, 313 (S.D.N.Y. 2009) (internal quotation marks omitted). The Court already considered and rejected the defendant's efforts to

ne 29, 2020. a grand jury in the Southern District of New York returned a six-count Indictment against the Defendant, charging her with facilitating Jeffrey Epstein's sexual abuse of multiple minor victims between approximately 1994 and 1997. See Dkt. No. 1. On July 2, 2020, the Indictment was unsealed, and that

t 30 years, might flee to the United Kingdom or France if granted bail, despite the fact that she did not leave the country for nearly a year after Epstein's arrest. (Dkt. 22 at 6.) The government asserted in its reply brief that France "does not extradite its citizens to the United States pursuant to F

eve of the one-year anniversary of the arrest of Jeffrey Epstein, creating the misimpression that Ms. Maxw

when denying bail. "A motion for reconsideration may not be used ... as a vehicle for relitigating issues already decided by the Court." Jackson v. Goord, 664 F. Supp. 2d 307, 313 (S.D.N.Y. 2009) (internal quotation marks omitted). The Court already considered and rejected the defendant's efforts to