3
Shared Docs
1
Same-Page
15 / 3
Mentions
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
by The Court notes that, regardless of which motion it considers, 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. 4
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
Page: HOUSE_OVERSIGHT_014803 →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
Page: HOUSE_OVERSIGHT_014807 →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
Page: HOUSE_OVERSIGHT_014828 →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
Page: HOUSE_OVERSIGHT_014652 →espectfully submit this Declaration in support of Ms. Maxwell’s Motion for Summary Judgment.’ 2. Attached as E
Page: HOUSE_OVERSIGHT_014652 →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
Page: HOUSE_OVERSIGHT_014661 →by ' The Court notes that, regardless of which motion it considers, 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
Page: HOUSE_OVERSIGHT_014681 →Entities connected to both Ghislaine Maxwell and Goston

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
United States
LOCATION
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Marc Rich
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSONLaura Menninger
PERSON
Virginia Giuffre
PERSONMaria Farmer
PERSONJane Doe
PERSONEmmy Taylor
PERSON
David Boies
PERSONSigrid McCawley
PERSON
U.S. Virgin Islands
LOCATION
Kenneth Marra
PERSON
Paul Cassell
PERSON
Paul Ryan
PERSON
Barack Obama
PERSON