Epstein Secrets

u regularly fly on Jeffrey's plane with individuals who were under the age of 18?.. . A. Can you repeat the question? Q. Did you regularly fly on Jeffrey Epstein's planes with individuals who were under the age of 18? A. I regularly flew on Jeffrey Epstein's airplane but I cannot testify as to flying with peo

. The Role of the Non-Party Witness in the Litigation 10 5. Other Factors Apart from the Non-Exclusive List. 10 C. Should Be Allowed to Call Epstein to Prevent the Jury from the Erroneous Conclusion that She Fears His Testimony. 15 II. ADMITTING EPSTEIN'S TESTIMONY IS NOT PREJUDICIAL OR CONFU

pstein's girlfriend at the relevant time: From: jeffrey E. <[email protected], Sent Thursday, January

one on the 11th you will see the column reading FBI in the ["]from["] column to TEB in the ["]to["] column and you will see some initials will see JE for Jeffrey Epstein, GM for Ghislaine Maxwell,. for and then n A. I have to object.... Q. Let me ask the question and if you have an issue -- so

e and Defendant were trafficking And even today, Defendant Epstein continues to be in a joint defense arrangement (

pstein's girlfriend at the relevant time: From: jeffrey E. <[email protected], Sent Thursday, January

is not a single piece of evidence suggesting that Mr. Epstein had any role in creating or publishing the conte

Deposit Co. of Maryland, 45 F.3d 969 (5th Cir. 1995) 6 In re WorldCom, Inc. Securities Litigation, 2005 WL 375315 (S.D.N.Y. Feb. 17, 2005) 17 LiButti v. United States, 107 F.3d 110 (2d Cir. 1997) passim Rules Fed. R. Evid. 611(c) 16 ii EFTA00622177 Plaintiff respectfully submits her repl

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff Case No. 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant JEFFREY EPSTEIN'S MOTION TO QUASH TRIAL SUBPOENA Jeffrey Epstein, a non-party to the above captioned action, has been subpoenaed to testify at the trial of this case

at the trial of this case, being commanded to appear on March 13, 2017. He now moves to quash that subpoena for the reasons set forth herein. Mr. Epstein was deposed by the parties on November 10, 2016. At that deposition, he asserted his Fifth Amendment privilege and declined to answer all substantiv

-cv-07433-RWS v. Ghislaine Maxwell, Defendant JEFFREY EPSTEIN'S MOTION TO QUASH TRIAL SUBPOENA Jeffrey

that subpoena for the reasons set forth herein. Mr. Epstein was deposed by the parties on November 10, 2016.

slave-scandal-that-exposed- pedophile-billionaire-jeffrey-epstein/ (last visited February 17, 2017); Newsweek, "Jeff

he party knows will assert his Fifth Amendment privilege, see, e.g., Brinks, Inc. v. City of New York, 717 F.2d 700, 708-10 (2d Cir. 1983); see also LiButti v. United States, 107 F.3d 110 (2d Cir. 1997), neither is this Court required to permit it in all cases. Instead, the question must be evaluated on

E OF CONTENTS INTRODUCTION 1 BACKGROUND 3 LEGAL AUTHORITY 5 I. PLAINTIFF'S LACK OF DILIGENCE 6 6 B. Ross Gow 9 C. Jean Luc Brunel 10 D. Jeffrey Epstein 12 E. and 14 II. FIFTH AMENDMENT BY EPSTEIN, OR NOT ADMISSIBLE IN THIS CASE AGAINST MS. MAXWELL 15 III. PLAINTIFF'S BAD FAITH DISCOVER

5 I. PLAINTIFF'S LACK OF DILIGENCE 6 6 B. Ross Gow 9 C. Jean Luc Brunel 10 D. Jeffrey Epstein 12 E. and 14 II. FIFTH AMENDMENT BY EPSTEIN, OR NOT ADMISSIBLE IN THIS CASE AGAINST MS. MAXWELL 15 III. PLAINTIFF'S BAD FAITH DISCOVERY TACTICS SHOULD NOT BE REWARDED WITH EXTRA TIME 18

ONS FOR VIOLATION OF RULE 45 Laura A. Menninger Jeffrey S. Pagliuca HADDON. MORGAN, AND FOREMAN, P.C. E

hat deposition in the Virgin Islands. Last week, Mr. Epstein's counsel filed a Motion to Quash his deposition

) 19 Grochowski v. Phoenix Const., 318 F.3d 80, 86 (2d Cir.2003). 5 lantosca v. Benistar Admin. Svcs., Inc., 765 F.Supp.2d 79 (D. Mass. 2011) 6 LiButti v. United States, 107 F.3d 110, 121 (2d Cir. 1997) 16 Murphy v. Board of Educ., 196 F.R.D. 220, 222 (W.D.N.Y.2000) 19 Perfect Pearl Co., Inc. v

ttorneys for Respondent Sharon Churcher BY: ERIC J. FEDER LAW OFFICES OF Attorneys BY: GREGORY L. RACHEL S. GREGORY L. POE PLLC for Respondent Jeffrey Epstein POE LI WAI SUEN SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA_R1_00024108 EFTA01737512 2 G6ndgium 4 5 6 7 8 9 10 11 12 13

on. We need to see what they're specifically talking about here. THE COURT: Thank you very much. I will reserve decision. The motion to quash the Epstein -- MR. POE: May I approach the podium, your Honor? THE COURT: Yes. Of course. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA_R1_00024133

N AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY PAGLIUCA LAURA A. MENNINGER DAVIS WRIGHT TREMAI

s whether in fact an undue burden would exist if Mr. Epstein were subjected at this point to a deposition. Th

t would not justify a deposition, which leaves really the Fifth Amendment implications that have been represented will be made, and that raises the LiButti issue. And under LiButti, your Honor, really the permeating factor is control. And the typical case -- really, most of the cases, to the extent co

. I don't think so. 10 MR. CASSELL: Let me just make sure that I have on the 11 table the things that we want to introduce. 12 For example, Mr. Epstein purchased a helicopter for 13 Ms. Maxwell, and they might say, oh, well, that shows financial 14 status or something. We think that shows a very

ings that we want to introduce. 12 For example, Mr. Epstein purchased a helicopter for 13 Ms. Maxwell, and

ing to conceal that from the jury or are we going to present 7 it to them? Well, the Second Circuit case that your Honor is 8 well familiar with, LiButti, sets out the factors that have 9 determined that issue, and one of the things we hear from the 10 defendant is, oh, it's never been applied in a

: Well, okay. I don't think so. MR. CASSELL: Let me just make sure that I have on the table the things that we want to introduce. For example, Mr. Epstein purchased a helicopter for Ms. Maxwell, and they might say, oh, well, that shows financial status or something. We think that shows a very close con

e things that we want to introduce. For example, Mr. Epstein purchased a helicopter for Ms. Maxwell, and they

we going to conceal that from the jury or are we going to present it to them? Well, the Second Circuit case that your Honor is well familiar with, LiButti, sets out the factors that have determined that issue, and one of the things we hear from the defendant is, oh, it's never been applied in a case l

: Well, okay. I don't think so. MR. CASSELL: Let me just make sure that I have on the table the things that we want to introduce. For example, Mr. Epstein purchased a helicopter for Ms. Maxwell, and they might say, oh, well, that shows financial status or something. We think that shows a very close c

e things that we want to introduce. For example, Mr. Epstein purchased a helicopter for Ms. Maxwell, and they

we going to conceal that from the jury or are we going to present it to them? Well, the Second Circuit case that your Honor is well familiar with, LiButti, sets out the factors that have determined that issue, and one of the things we hear from the defendant is, oh, it's never been applied in a case l