Epstein Secrets

e reasons, the Court should deny the motion of Jane Doe 1 and Jane Doe 2 to discover and use the plea negotiation letters as evidence. PART II MR. EPSTEIN'S PLEA NEGOTIATIONS ARE PRIVILEGED AND NOT DISCOVERABLE UNDER RULE 501 Jane Doc 1 and Jane Doe 2 are also not entitled to discovery or use of the p

entity of the interviewing agents and the nature of the interview, WILD provided the following information: In 2003 or 2004 WILD was introduced to JEFFREY EPSTEIN for the purpose of providing him with personal massages. WILD was approached at a party by a female she believoi was named CHARLISE. She described

onths, one week and 3 days. EFTA00178032 FD-302a (Rev. 10-6-95) 31E-MM-108062 Continuation of FD-302 of Shawna Lane Rivera .On 05/28/2008 ,Page Epstein offered to pay an extra $100.00 to Rivera if she brought additional girls to him. Epstein asked Rivera to provide a massage to Sarah LNU but the ma

ormation: In 2003 or 2004 WILD was introduced to JEFFREY EPSTEIN for the purpose of providing him with pe

e plea negotiation letters as evidence. PART II MR. EPSTEIN'S PLEA NEGOTIATIONS ARE PRIVILEGED AND NOT DISCO

. WILD stated that one of the girls she stayed with on occasion, AMY FOREMAN, also started providing EPSTEIN with massages. A telephone number for FOREMAN was (561)718-1924. WILD said that her family resides in Wellington, Florida, possibly Crestwood. WILD also stayed with JACLYN REGOLI during this sa

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

ING DEADLINE TO COMPLETE DEPOSITIONS AND MOTION FOR SANCTIONS FOR VIOLATION OF RULE 45 Laura A. Menninger Jeffrey S. Pagliuca HADDON. MORGAN, AND FOREMAN, P.C. East 10th Avenue Denver, CO 80203 303.831.7364 EFTA00605112 Case 1:15-cv-07433-RWS Document 228 Filed 06/20/16 Page 2 of 29 TABLE OF CON

onfidentiality provision of the settlement agreement as requested by Plaintiff. Mr. Poe, Mr. Epstein's counsel stated "I am authorized to state that Jeffrey Epstein is willing to agree not to sue plaintiff's counsel/plaintiff if the settlement agreement is disclosed to defendant Maxwell's counsel provided that (

Epstein. Initially, Plaintiff improperly conditioned production of the document by requiring that counsel for Ms. Maxwell obtain a "waiver from Mr. Epstein." Although it was not Ms. Maxwell's burden to do so, in an attempt to avoid filing this Motion, counsel for Ms. Maxwell obtained the waiver from co

COMPEL SETTLEMENT AGREEMENT Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. 1

hat counsel for Ms. Maxwell obtain a "waiver from Mr. Epstein." Although it was not Ms. Maxwell's burden to do

fendant. X 15-cv-07433-RWS DEFENDANT'S RENEWED MOTION TO COMPEL SETTLEMENT AGREEMENT Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. 150 East 10i° Avenue Denver, CO 80203 303.831.7364 EFTA_R1_00013286 EFTA01734801 Case 1:15-cv-07433-RWS Document 422 Filed 09/06/16 Page

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

District Judge APPEARANCES BOIES, SCHILLER & FLEXNER LLP Attorneys for Plaintiff BY: SIGRID S. McCAWLEY MEREDITH L. SCHULTZ HADDON MORGAN AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY PAGLIUCA LAURA A. MENNINGER DAVIS WRIGHT TREMAINE LLP Attorneys for Respondent Sharon Churcher BY: ER

basis of such privileges. DOCUMENT REQUEST NO. 8 Produce any documents concerning any of Your, or Your attorneys or agent's, communications with Jeffrey Epstein's attorneys or agents from 1999 to the present relating to the issue of sexual abuse of females, or any documents concerning any of Your, Your attorne

time frame that Plaintiff was abused by Jeffrey Epstein; (3) that the allegations were made against a num

the same time frame that Plaintiff was abused by Jeffrey Epstein; (3) that the allegations were made again

conferral. Dated: May 16, 2016 Respectfully submitted, s/Laura A.Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) AND FOREMAN, P.C. Denver, CO 80203 Phone: Fax: Attorneys for Ghislaine Maxwell 23 EFTA00091375 CERTIFICATE OF SERVICE I certify that on May 16, 2016, I

she would not provide any information regarding JEFFREY EPSTEIN. The interviewing agent provided RIVERA

, FD-302a (Rev. 10-6-95) 31E-MM-108062 ComaimMionSM2a Courtney Wild .On 08/07/2007 .Page 2 girls she could bring. When EPSTEIN telephoned, he usually asked for WILD to come over., According to WILD, EPSTEIN's house telephone number began with the digits 655. She would call

vised of the identity of the interviewing agent and the nature of the interview, RIVERA stated that she would not provide any information regarding JEFFREY EPSTEIN. The interviewing agent provided RIVERA with FBI contact information. RIVERA was informed to contact the FBI should she decide to cooperate with au

. WILD stated that one of the girls she stayed with on occasion, AMY FOREMAN, also started providing EPSTEIN with massages. A telephone number for FOREMAN was (561)718-1924. WILD said that her family resides in Wellington, Florida, possibly Crestwood. WILD also stayed with JACLYN REGOLI during this sa

tion Designated Confidential Laura A. Menninger Jeffrey S. Pagliuca HADDON. MORGAN, AND FOREMAN, P.C. E

ssinsider.com/how-alan-dershowitz-got-involved-in-jeffrey-epstein-case- 2015-1 (last visited April 6, 2016). In ad

otection Order to Restrict Mr. Edwards's Access to Information Designated Confidential Laura A. Menninger Jeffrey S. Pagliuca HADDON. MORGAN, AND FOREMAN, P.C. East 10th Avenue Denver, CO 80203 EFTA00595640 Case 1:15-cv-07433-RWS Document 88 Filed 04/08/16 Page 2 of 7 INTRODUCTION Defendant Ghis

tion Designated Confidential Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. E

ssinsider.com/how-alan-dershowitz-got-involved-in-jeffrey-epstein-case- 2015-1 (last visited April 6, 2016). In ad

otection Order to Restrict Mr. Edwards's Access to Information Designated Confidential Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. East 10th Avenue Denver, CO 80203 EFTA00595633 Case 1:15-cv-07433-RWS Document 88 Filed 04/08/16 Page 2 of 7 INTRODUCTION Defendant Ghisl

he ECF system. SERVICE LIST Laura A. Menninger Jeffrey S. Pagliuca (Pro Hac Vice) HADDON MORGAN AND FOR

all counsel of record listed below through the ECF system. SERVICE LIST Laura A. Menninger Jeffrey S. Pagliuca (Pro Hac Vice) HADDON MORGAN AND FOREMAN 150 East 10th Avenue Denver, CO 80203 Telephone: (303)-831-7364 Fax: (303)-832-2628 Email: [email protected] Email: [email protected] A