Epstein Secrets

eclare as follows: 1. Iam an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. Iam a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit

uests were horrified,’ said the article's author, Vicky Ward. it should not be forgotten that Epstein is

a guest at a cocktail party thrown by Epstein and Maxwell packed with young Russian models. ‘Some guests were horrified,’ said the article's author, Vicky Ward. it should not be forgotten that Epstein is a registered sex offender after recently completing his sentence for offences relating to child prostitu

rs, the same standard governs the addition of parties under Rule 21 and Rule 15. See Goston v. Potter, No. 08-cv-478 FJS ATB, 2010 WL 4774238, at *5 (N.D.N.Y. 2010) (citing Bridgeport Music, Inc. v. Universal Music Grp., Inc., 248 F.R.D. 408, 412 (S.D.N.Y. 2008)). 4 GIUFFRE002847 HOUSE_OVERSIGHT_014680

y 2005, the FBI and the U.S. Attorney’s Office in the Southern _ District of Florida learned of Epstein’s repeated sexual a

person outside of my immediate family that I send drafts to is Jeffrey” The 29 HOUSE_OVERSIGHT_010594 --- PAGE BREAK --- Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Work, Vanity Fair (See article attached as Exhibit “OO”); (c) Epstein’s housekeeper Alfredo Rodriguez testified that De

594 --- PAGE BREAK --- Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Work, Vanity F

agreed that he would not contest jurisdiction in the Southern District of Florida for any victim who chose to sue him fo

347 --- PAGE BREAK --- Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Work, Vanity F

person outside of my immediate family that I send drafts to is Jeffrey” The 29 HOUSE_OVERSIGHT_013347 --- PAGE BREAK --- Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Work, Vanity Fair (See article attached as Exhibit “OO”); (c) Epstein’s housekeeper Alfredo Rodriguez testified that De

pstein, case number 08-80893 in: federal Court in the Southern District of Florida. | am the lead attorney representing °

comments that, “I’m on my 20th book... The only person outside of my immediate family that I send drafts to is Jeffrey” The Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Work, Vanity Fair; (c) Epstein’s housekeeper Alfredo Rodriguez testified that Dershowitz stayed at Epstein’s house duri

rafts to is Jeffrey” The Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Work, Vanity F

s sexual trafficking victims in a case pending in the Southern District of Florida, specifically case no. 08-cv-80736- KA

a guest at a cocktail party thrown by Epstein and Maxwell packed with young Russian models. ‘Some guests were horrified,’ said the article’s author, Vicky Ward. It should not be forgotten that Epstein is a registered sex offender after recently completing his sentence for offences relating to child prostitu

uests were horrified,’ said the article’s author, Vicky Ward. It should not be forgotten that Epstein is