Epstein Secrets

United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. NOTICE OF SERVICE OF RULE 45 SUBPOENA UPON SHOPPER'S TRAVEL, INC. PLEASE TAKE NOTICE THAT, pursuant to Rule 45 of the Federal Rules of

ff' in the above captioned action shall mean the plaintiff formerly known as 4. "Defendant" in the above captioned action shall mean the defendant Ghislaine Maxwell and her employees, representatives or agents. 5. "Document" shall mean all written and graphic matter, however produced or reproduced, an

above captioned action shall mean the plaintiff formerly known as 4. "Defendant" in the above captioned action shall mean the defendant Ghislaine Maxwell and her employees, representatives or agents. 5. "Document" shall mean all written and graphic matter, however produced or reproduced, and each an

e. Dated: April 27, 2016 By: /s/ Sigrid McCawley Sigrid McCawley (Admitted Pro Hac Vice) Boies Schiller & Flexner LLP Ft. Lauderdale. FL 33301 Ellen Brockman Boles Schiller & Flexner LLP New York. New York 10022 EFTA00078793 AO 8813 (Rev. 12/13) Subpoena to Produce Documents, Information. or Objects o

-RWS Document 89 Filed 04/10/16 Page 1 of 10 United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF, CONSOLIDATED REPLY IN OPPOSITION TO DEFENDANT'S MOTIONS TO DISOALIFY PROFESSOR CASSELL AND MR. EDWARDS FROM REPRESENTING

intiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF, CONSOLIDATED REPLY IN O

York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF, CONSOLIDATED RE

Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boles Boles, Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Ellen Brockman Boles, Schiller & Flexner LLP 575 Lexington Ave New York, New York 10022 (212) 446-2300 Paul Cassell (Seeking Pro Hac Vice) S.J. Quinney Colleg

United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. NOTICE OF SERVICE OF RULE 45 SUBPOENA UPON SHOPPER'S TRAVEL. INC. PLEASE TAKE NOTICE THAT, pursuant to Rule 45 of the Federal Rules of

ff' in the above captioned action shall mean the plaintiff formerly known as 4. "Defendant" in the above captioned action shall mean the defendant Ghislaine Maxwell and her employees, representatives or agents. 5. "Document" shall mean all written and graphic matter, however produced or reproduced, an

above captioned action shall mean the plaintiff formerly known as 4. "Defendant" in the above captioned action shall mean the defendant Ghislaine Maxwell and her employees, representatives or agents. 5. "Document" shall mean all written and graphic matter, however produced or reproduced, and each an

Sigrid McCawley (Admitted Pro Hac Vice) Boles Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 Ellen Brockman Boles Schiller & Flexner LLP 575 Lexington Ave New York, New York 10022 (212) 446-2300 EFTA00601141 AO 8813 (Rev. 12/13) Subpoena to Produce D

United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT GHISLAINE MAXWELL Plaintiff, by and through her undersigned counse

intiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT GHISLAINE MAXWELL Plaintiff, by and through her undersigned counsel, hereby propounds Plaintiff's First Request for Production of Documents pursuant to Rules 26 and

each Florida between the years 1999 and 2002. DOCUMENT REOUEST NO. 36 All documents you rely upon to establish that (a) sworn allegations "against Ghislaine Maxwell are untrue." (b) the allegations have been "shown to be untrue."; and (c) "claims are obvious lies." DOCUMENT REQUEST NO. 37 All document

Sigrid McCawley (Pro Hac Vice Pending) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 Ellen Brockman Boies Schiller & Flexner LLP 575 Lexington Ave New York, New York 10022 (212) 446-2300 12 EFTA00605871 CERTIFICATE OF SERVICE I HEREBY CERTI

Case 1:15-cv-07433 Document 1 Filed 09/21/15 Page 1 of 12 United States District Court Southern District of New York Plaintiff, CASE NO: v. GHISLAINE MAXWELL, Defendant. COMPLAINT Boles Schiller & Flexner LLP 575 Lexington Avenue New York. NY 10022 EFTA00676990 Case 1:15-cv-07433 Document 1

1:15-cv-07433 Document 1 Filed 09/21/15 Page 2 of 12 Plaintiff, , formerly known as In), for her Complaint against Defendant, GHISLAINE MAXWELL ("Maxwell"), avers upon personal knowledge as to her own acts and status and otherwise upon information and belief: NATURE OF THE ACTION 1. This suit aris

a citizen of the state of Colorado. FACTUAL ALLEGATIONS 8. became a victim of sex trafficking and repeated sexual abuse after being recruited by Ghislaine Maxwell and Jeffrey Epstein whe of eighteen. 9. vas under the age Between 1999 and 2002, with the assistance and participation of Maxwell, Epstein sexua

ed September 21, 2015. /s/ David Boies David Boies Boies Schiller & Flexner LLP /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice Pending) /s/ Ellen Brockman Ellen Brockman Boies Schiller & Flexner LLP 12 EFTA00677001

cv-07433 Document1 Filed 09/21/15 Page 1 of 12 United States District Court Southern District of New York VIRGINIA L. GIUFFRE, Plaintiff, CASE NO: V. GHISLAINE MAXWELL, Defendant. / COMPLAINT Boies Schiller & Flexner LLP 575 Lexington Avenue New York, NY 10022 (212) 446-2300 HOUSE_OVERSIGHT_015531 --- PAGE BREA

age 2 of 12 Plaintiff, VIRGINIA L. GIUFFRE, formerly known as Virginia Roberts (“Giuffre”), for her Complaint against Defendant, GHISLAINE MAXWELL (“Maxwell”), avers upon personal knowledge as to her own acts and status and otherwise upon information and belief: NATURE OF THE ACTION 1. This suit arises o

o cause the world to disbelieve Giuffre; and to destroy Giuffre’s efforts to use her experience to help others suffering as sex trafficking victims. Se Maxwell, personally and through her authorized agent, Ross Gow, intentionally and maliciously made false and damaging statements of fact concerning Giuffre,

5-cv-07433-LAP Document 1 Filed 09/21/15 Page 2 of 12 Plaintiff, formerly known as (a'), for her Complaint against Defendant, GHISLAINE MAXWELL ("Maxwell"), avers upon personal knowledge as to her own acts and status and otherwise upon information and belief: NATURE OF THE ACTION 1. This suit aris

d repeated sexual abuse after being recruited by Ghislaine Maxwell and Jeffrey Epstein when was under the a

egations have been "shown to be untrue." (c) That "claims are obvious lies." 31. Maxwell's January 3, 2015, statement incorporated by reference "Ghislaine Maxwell's original response to the lies and defamatory claims remains the same," an earlier statement that had falsely described factual assertions as "ent