Epstein Secrets

UNITED 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 per

to repeat his assertion of his Fifth Amendment privilege. Second, plaintiff argues that Mr. Epstein should be required to appear because defendant Maxwell has objected to the use of Mr. Epstein's deposition testimony, claiming that he is not an unavailable witness. Response at 3. This is simply a non-i

Case No. 15-cv-07433-RWS v. HEARING REQUESTED Ghislaine Maxwell, Defendant JEFFREY EPSTEIN'S REPLY TO P

intiff's case in chief. Nor does speculation that Ms. Maxwell might object to the authenticity of the "blackbo

the matter on trial, but that is not the case here. In neither United States v. International Bus. Machines Corp., 90 F.R.D. 377 (S.D.N.Y. 1981), or Napier v. 1 EFTA00589510 Bassard, 102 F.2d 467 (2d Cir. 1939), on which the plaintiff relies, Response at 2, did the witnesses at issue assert their Fi

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 plaint

to repeat his assertion of his Fifth Amendment privilege. Second, plaintiff argues that Mr. Epstein should be required to appear because defendant Maxwell has objected to the use of Mr. Epstein's deposition testimony, claiming that he is not an unavailable witness. Response at 3. This is simply a non-i

ERN DISTRICT OF NEW YORK Plaintiff Case No v. Ghislaine Maxwell, Defendant JEFFREY EPSTEIN'S REPLY TO P

intiff's case in chief. Nor does speculation that Ms. Maxwell might object to the authenticity of the "blackbo

the matter on trial, but that is not the case here. In neither United States v. International Bus. Machines Corp., 90 F.R.D. 377 (S.D.N.Y. 1981), or Napier v. Bassard, 102 F.2d 467 (2d Cir. 1939), on which the plaintiff relies, Response at 2, did the witnesses at issue assert their Fifth Amendment priv

e should fit together in this way, and in fact it wasn't until many years later that the equation was independently explained at an atomic level by Maxwell and Boltzmann. Thirdly, the equations do not refer to underlying microscopic mechanisms or variables. In equation (4.7a) there are no references to

l regularity and predictability in the aggregate. The Maxwell-Boltzmann-Gibbs methods of statistical mechanics

becomes a much more powerful theoretical method than neoclassicism. The economic historians such as Reinhart & Rogoff, Shiller, Smithers, Harrison, Napier and Bernholz have the advantage of the long sweep of history to prevent them from accepting high- faluting theory that disagrees with reality. This

ssipative structure approach, presumably there is a negentropy flow associated with 'maintaining' the dissipative structure in its low entropy form; Maxwell's demon is continually at work narrowing the spread of the distribution. However if this negentropy flow is smaller than the entropy flow through t

distribution [Levy & Solomon 1996]. In contrast the Maxwell-Boltzmann distribution of a normal thermodynamic

002. Macroeconomics, Understanding the Wealth of Nations. John Wiley and Sons. 287 EFTA00625415 Mirowski 1989 Mirowski 2010 Mitzenmacher 2004 Napier 2007 NEA 2010 Newman 2005 New Scientist 2008 Nirei & Souma 2007 Nise 2000 Norton Ariely 201 Noser 2010 ONS 2003 ONS 2004 Ozawa et al 2003