Epstein Secrets

ITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff Case No. 15-cv-07433-RWS v. HEARING REQUESTED Ghislaine Maxwell, Defendant JEFFREY EPSTEIN'S REPLY TO PLAINTIFF'S RESPONSE TO HIS MOTION TO QUASH TRIAL SUBPOENA Mr. Epstein respectfully requests that he be permitted to be heard on his Motio

WS v. HEARING REQUESTED Ghislaine Maxwell, Defendant JEFFREY EPSTEIN'S REPLY TO PLAINTIFF'S RESPONSE TO HIS MOTION TO QUASH TRIAL SUBPOENA Mr. Epstein respectfully requests that he be permitted to be heard on his Motion to Quash. Far from being an "important witness," as plaintiff asserts, Jeffrey

HEARING REQUESTED Ghislaine Maxwell, Defendant JEFFREY EPSTEIN'S REPLY TO PLAINTIFF'S RESPONSE TO HIS MO

RESPONSE TO HIS MOTION TO QUASH TRIAL SUBPOENA Mr. Epstein respectfully requests that he be permitted to be

mpel the Production of Documents and Testimony from Jeffrey Epstein at 8-9 & n.4. 4 EFTA00589513 needed to prosecute [him] for a federal crime." Rajah v. Mukasey, 544 F.3d 427, 441 (2d Cir. 2008), quoting United States v. Hubbell, 530 U.S. 27, 38 (2000). See, e.g., United States v. Greenfield, 831 F.3d 106,

, which has been consolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when

nsolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when the girls

requests for production that were propounded on Defendant Epstein. Defendant has responded by asserting several obj

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 0

d passports, considered by the courts to be "required records," are as a matter of law deemed not subject to Fifth Amendment protection. See, e.q., Rajah v. Mukasey, 544 F.3d 427, 442 (2d Cir. 2008)("Just as a taxpayer's W-2 forms are required records not subject to the Fifth Amendment because they are a mandat

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff Case No v. Ghislaine Maxwell, Defendant JEFFREY EPSTEIN'S REPLY TO PLAINTIFF'S RESPONSE TO HIS MOTION TO QUASH TRIAL SUBPOENA Far from being an "important witness," as plaintiff asserts, Jeffrey Epstein wo

he jury. Plaintiff has not provided the Court with any reason which withstands scrutiny as to why it would further the interests of justice for Mr. Epstein to be compelled to appear personally to assert his Fifth Amendment privilege. Indeed, the weakness of plaintiff's arguments provides additional com

tiff Case No v. Ghislaine Maxwell, Defendant JEFFREY EPSTEIN'S REPLY TO PLAINTIFF'S RESPONSE TO HIS MO

hy it would further the interests of justice for Mr. Epstein to be compelled to appear personally to assert hi

laces where nude photographs might be found) would plainly "furnish a link in the chain of evidence needed to prosecute [him] for a federal crime." Rajah v. Mukasey, 544 F.3d 427, 441 (2d Cir. 2008), quoting United States v. Hubbell, 530 U.S. 27, 38 (2000). See, e.g., United States v. Although plaintiff has arg