Epstein Secrets

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

Rich: A Powerful Billionaire, the Sex Scandal that Undid Him, and All the Justice that Money Can Buy - The Shocking True Story of Jeffrey Epstein (Little, Brown & Co. October 10, 2016). His personal appearance at the trial of this case would predictably be the focus of massive media attention, of both the main-str

2116 FAX NI it EN Y December 3, 2015 Via Hand Delivery Little, Brown & Co. Market Place Center Boston, MA 02108 RE: Proposed Book Reeardine Jeffery Epstein Dear Sir or Madam: I have been informed by John Connolly, as well as several others who Mr. Connolly has contacted, that a book is being authored

as several others who Mr. Connolly has contacted, that a book is being authored by Mr. Connolly about my client, Jeffrey Epstein. In the past, Mr. Epstein has been the subject of widespread and often seriously inaccurate and untruthful media coverage. It would be in reckless disregard for the truth if

s being authored by Mr. Connolly about my client, Jeffrey Epstein. In the past, Mr. Epstein has been the s

y about my client, Jeffrey Epstein. In the past, Mr. Epstein has been the subject of widespread and often seri

einberg& MARTIN G. WEINBERG, ATTORNEY AT LAW EMAIL ADDRESSES: BOSTON, MASSACHUSETTS 02116 FAX NI it EN Y December 3, 2015 Via Hand Delivery Little, Brown & Co. Market Place Center Boston, MA 02108 RE: Proposed Book Reeardine Jeffery Epstein Dear Sir or Madam: I have been informed by John Connolly, as w

02116 FAX NI R FN Y December 3, 2015 Via Hand Delivery Little, Brown & Co. Market Place Center Boston, MA 02108 RE: Proposed Book Reeardine Jeffery Epstein Dear Sir or Madam: I have been informed by John Connolly, as well as several others who Mr. Connolly has contacted, that a book is being authored

as several others who Mr. Connolly has contacted, that a book is being authored by Mr. Connolly about my client, Jeffrey Epstein. In the past, Mr. Epstein has been the subject of widespread and often seriously inaccurate and untruthful media coverage. It would be in reckless disregard for the truth if

s being authored by Mr. Connolly about my client, Jeffrey Epstein. In the past, Mr. Epstein has been the s

y about my client, Jeffrey Epstein. In the past, Mr. Epstein has been the subject of widespread and often seri

Weinberg& MARTIN G. WEINBERG, ATTORNEY AT LAW EMAIL ADDRESSES: BOSTON, MASSACHUSETTS 02116 FAX NI R FN Y December 3, 2015 Via Hand Delivery Little, Brown & Co. Market Place Center Boston, MA 02108 RE: Proposed Book Reeardine Jeffery Epstein Dear Sir or Madam: I have been informed by John Connolly, as w

SETTS 02116 May 3, 2016 Via Electronic Mail Eric Rayman, Esq. Miller, Korzenik, Sommers, Rayman LLP 488 Madison Avenue New York, NY 10022 Re: Jeffrey Epstein Dear Mr. Rayman: I have reviewed your letter of May 2, 2016, that was emailed to Mr. Weingarten and myself. First, to address the unnecessary and

d be in the self- interest of any publisher to provide the subject of an intended book (such as the one that has been or is being authored about Mr. Epstein) with the prior opportunity to check its accuracy so that unambiguous factual errors could be corrected thus reducing the potential for both future

LLP 488 Madison Avenue New York, NY 10022 Re: Jeffrey Epstein Dear Mr. Rayman: I have reviewed your l

the one that has been or is being authored about Mr. Epstein) with the prior opportunity to check its accuracy

eviewed your letter of May 2, 2016, that was emailed to Mr. Weingarten and myself. First, to address the unnecessary and inaccurate assertions about Little, Brown & Co. never receiving my letter of December 3, 2015 that was addressed to them at the former 3 Center Plaza Boston address, please be advised that a curr