Epstein Secrets

Boies it was issued. The materials provided by Boies Schiller inclnin addition tIl inscripts of Maxwell and other individuals, materials proday N/14!IME lles, and court-relatedpleadings in the ase. 7. Magistrate Juda jOrder On or about April 9, 201

on in ordering the unsealing of the deposition materials and that Maxwell's interests outweighed the public's interests in access to the materials. n. Maxwell, No.20-2413 (2d Cir.), (Dkt. No. 140-1 at 2). On October 19, 2020, the Second Circuit found that Judge Preska "correctly held that the deposition ma

eeting in the summer of 2016 after Maxwell allegedly 35 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020, https://www.nydailynews.corninew-york/ny-jeffrey-epstein-maxwell-case-20201013- jmzh17zdr

osecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily New

al. On February 8, 2021, Judge Preska "decline[d] Ms. Maxwell's invitation to reconsider its order" and noted

er assertion that was instrumental in fomenting the Maxwell prosecution" (Def. Mot 3 at 2) (emphasis in orig

reciable deterrence." United States v. Eldred, 933 F.3d 110, 118 (2d Cir. 2019) (quotingHerring v. Un ited States,555 U.S. 135, 141(2009)); see also Herring, 555 U.S. at 144 (concluding that "[t]o trigger the exclusionary rule, police conduct must be sufficiently deliberate that exclusion can meaningful

299 Park Avenue 25th Roor New York IV 10171.0002 CNP7006552645091i X12 YI 0 Account name GHISLANE MAXWELL UBS Strategic Advisor September 2014 OHISLAINE MAXWELL 116 E 65TH STREET NEW YORK NY 10065.7007 Your if nandal Advisor: SCOTT STACKMANrLYI£ CASRIEL Phone: 212-821-7000/800-308-3140 Questions about y

of accrued interest 94568.05 00 Change in market value 418962.05 Ain 2014 Apr 2014 Value of your scant on Apr 30, 2014 $4800.158.85 SDNY GM 00022184 Member SIPC C NP70302009938697 NP7003191 745 00036 0414 030575004 m3574550000000 Page 65 of 08 CONFIDENTIAL EFTA 00132%04 EFTA01274941

his document for details about those balances. Hddng Cash LIBS BANK USA CEP ACCT Total Openngbdance Closing Wane on Apr 1 (1) en Apr 30 IS) GHISLAINE MAXWELL Pnce per Mace on Apr 30 (1) Average rate Drildenl interest period Your Nnandri Advisor: SCOTT STACKMANLYLE CASRIEL 212821-70001800-3

0 38.970 77,9.10 00 -12,380.00 51 Total 1,203,574.03 1182,385.13 -121,187.90 Total estimated annual income: $1,976 Account name: GHISLAINE MAXWELL Your /I sandal Advisor: SCOTT STACKMANLYLE CASRIEL 212-821-70001800-308-3140 Closed end funds & Exchange traded products Total reinvested is the

CONFIDENTIAL EFTA_00132830 EFTA01274967 SUBS Resource Management Account May 2014 Your assets Your total assets (continued) Account name: GHISI AINE MAXWELL Your A Bendel Advisor: SCOTT STACKMAI/LYLE CASRIEL 212-821.7000/800-308.3140 Ydue on Miff 30 (1) Percenta,v of Cost your couni NUS (S) Esur

t also does not include cash I:.m:fends that were rat *Infested Cost PrKe per Share basis (S) on May 30(4) value on unrealized Rain iniemment Herring May 30 (3) gain or loss (3) return (3) Period 190.000 168.060 31,931 40 31,931.40 120.430 22,881.70 -9,04970 -9.04970 LT 0070300305631

provided to Boies Schiller shortly after it was issued. The materials provided by Boies Schiller included, in addition to deposition transcripts of Maxwell and other individuals, materials produced by Maxwell, and non-parties, and court-related pleadings in the civil case. 7. Magistrate Judge Netburn

eeting in the summer of 2016 after Maxwell allegedly 35 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020, hftps://www.nydailynews.cominew-yorlc/ny-j effrey-epstein-maxwel I-case-20201013- jrnzhl7

al. On February 8, 2021, Judge Preska "decline[d] Ms. Maxwell's invitation to reconsider its order" and noted

osecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily New

hat "Boies Schiller was instrumental in fomenting the Maxwell prosecution" (Def. Mot. 3 at 2) (emphasis in ori

ciable deterrence." United States v. Eldred, 933 F.3d 110, 118 (2d Cir. 2019) (quoting Herring v. United States, 555 U.S. 135, 141 (2009)); see also Herring, 555 U.S. at 144 (concluding that "[t]o trigger the exclusionary rule, police conduct must be sufficiently deliberate that exclusion can meaningful

provided to Boies Schiller shortly after it was issued. The materials provided by Boies Schiller included, in addition to deposition transcripts of Maxwell and other individuals, materials produced by Giuffre, Maxwell, and non-parties, and court-related pleadings in the civil case. 7. Magistrate Judge

eeting in the summer of 2016 after Maxwell allegedly 35 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020, https://wwvv.nydailynews.corninew-yorlc/ny-jeffity-epstein-maxwell-case-20201013- jrnzhl7

al. On February 8, 2021, Judge Preska "decline[d] Ms. Maxwell's invitation to reconsider its order" and noted

osecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily New

hat "Boies Schiller was instrumental in fomenting the Maxwell prosecution" (Def. Mot. 3 at 2) (emphasis in ori

ciable deterrence." United States v. Eldred, 933 F.3d 110, 118 (2d Cir. 2019) (quoting Herring v. United States, 555 U.S. 135, 141 (2009)); see also Herring, 555 U.S. at 144 (concluding that "[t]o trigger the exclusionary rule, police conduct must be sufficiently deliberate that exclusion can meaningful

provided to Boies Schiller shortly after it was issued. The materials provided by Boies Schiller included, in addition to deposition transcripts of Maxwell and other individuals, materials produced by Giuffre, Maxwell, and non-parties, and court-related pleadings in the civil case. 7. Magistrate Judge

eeting in the summer of 2016 after Maxwell allegedly 35 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020, https://wwvv.nydailynews.corninew-yorlc/ny-jeffity-epstein-maxwell-case-20201013- jrnzhl7

al. On February 8, 2021, Judge Preska "decline[d] Ms. Maxwell's invitation to reconsider its order" and noted

osecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily New

hat "Boies Schiller was instrumental in fomenting the Maxwell prosecution" (Def. Mot. 3 at 2) (emphasis in ori

ciable deterrence." United States v. Eldred, 933 F.3d 110, 118 (2d Cir. 2019) (quoting Herring v. United States, 555 U.S. 135, 141 (2009)); see also Herring, 555 U.S. at 144 (concluding that "[t]o trigger the exclusionary rule, police conduct must be sufficiently deliberate that exclusion can meaningful

materials. Giuf•e v. Maxwell, No. 20-2413 (2d Cir.) (Dkt. No. 140-1 at 2). On October 19, 2020, the Second Circuit found that Judge Preska "correctly held that the deposition ma

as "insist[ing] [a second meeting] never happened." 36 See Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily News, Oct. 13, 2020, https://wwvv.nydailynews.corninew-yorlc/ny-jeffrey-epstein-maxwell-case-20201013- jrnzhl7

al. On February 8, 2021, Judge Preska "decline[d] Ms. Maxwell's invitation to reconsider its order" and noted

osecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016: sources, New York Daily New

her assertion that was instrumental in fomenting the Maxwell prosecution" (Def. Mot. 3 at 2) (emphasis in ori

ciable deterrence." United States v. Eldred, 933 F.3d 110, 118 (2d Cir. 2019) (quoting Herring v. United States, 555 U.S. 135, 141 (2009)); see also Herring, 555 U.S. at 144 (concluding that "[t]o trigger the exclusionary rule, police conduct must be sufficiently deliberate that exclusion can meaningful

e.24h24/43134.01FrietibtOrtlefifitin0a0le28013,8111$2eafiabef146f 22 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Reply In Support Of Iler Objections to tnsealinu Sealed Materials Laura A. Menninger Jeffre

iabef146f 22 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Reply In Support Of Iler Objections to tnsealinu Sealed Materials Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C

ine Maxwell says she was Epstein's employee not his madam," MIAMI HERALD (Mar. 18, 2020) (quoting Sigrid McCawley, "It is absolutely appalling that Ghislaine Maxwell, who committed crimes with Epstein against these victims, is seeking to drain funds from the very estate that should be paying the Epstein victims'

ISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Reply In Support Of Iler Objections to tnsealin

ssible, and non-cumulative evidence that advances that determination, but their participation as listed parties is not necessary in that regard. See Herring, 894 F.2d at 1024 (District court did not abuse its discretion by denying amendment where "addition of more plaintiffs . . . would not have affecte

ons with her, which he denies. Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. Ghislaine Maxwell's original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared

lying in a hammock.‘We all dined together that night. Jeffrey was at the head of the table. Bill was at his left. | sat across from him. Emmy Tayler, Ghislaine’s blonde British assistant, sat at my right. ‘Ghislaine was at Bill’s left and at the left of Ghislaine there were two olive-skinned brunettes who'd

ricen businessmen Jeffrey Epstein end his friends. Bulnness with William after his wild Hime ' Te ‘ ing in Switzerland Later, she claims, Fpatein’s frienel Ghislsing Maxwell tale her: Yeu did wel. Ae hae! era hy — fun: Smoke break! Weary- Kae and Ashley Slsan enjoy a cigarette outside New ‘Tork Gly office building after

n, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit this Declaration in support of Ms. Maxwell’s Motion for Summary Judgment.’ 2. Attached as Exhibit A is a true and correct copy of an article by Sharon Churcher entitled “Prince Andrew and the

espectfully submit this Declaration in support of Ms. Maxwell’s Motion for Summary Judgment.’ 2. Attached as E

ives most concern. mon ey. | was a He was first seen with the pair on holiday in “Tt Thailand, and was pictured cavorting with paed Oop hile's dream Ghislaine at a Halloween fetishthemed party in hitp:/Avww.dailymail.co.uk/news/article-1361039/Prince-Andrew-girl-17-sex-offender-friend-flew-Britain-meet-him

uire amendment where the addition of parties with duplicative claims will not materially advance the resolution of the litigation on the merits. See Herring v. Delta Air Lines, Inc., 894 F.2d 1020, 1024 (9th Cir. 1989). A. Rule 21 Motion Jane Doe 3 and Jane Doe 4’s first attempt to join in this proceedi