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burn, We write today to request a pre-motion conference, pursuant to Local Civil Rule 37.2, to seek the Court's guidance as to compelling defendant Maxwell to produce requested documents. As the Court will recall, this is a case in which the plaintiff,M has alleged that she was sexually trafficked by
this is a case in which the plaintiff,M has alleged that she was sexually trafficked by Jeffrey Epstein and his co-defendants, including defendant Ghislaine Maxwell. Maxwell is the only one of the four defendants who did not invoke her Fifth Amendment right against self-incrimination to refuse to produce docume
ts. But in response to requests for production, Ms. Maxwell produced very little information. Following that
stein and his co-defendants, including defendant Ghislaine Maxwell. Maxwell is the only one of the four def
Case 1:17-cv-00616-JGK-SN Document 179 Filed 12/13/18 Page 1 of 14 PAUL G. CASSELL Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah 383 S. University St. Salt Lake Cit UT 84112 Tele ho
al Law Telephone: 801-585-5202 [email protected] New Scotland Yard London SW1H 0BG Re: International Sex Trafficking by Jeffrey Epstein and Ghislaine Maxwell Ref: AC/SCO/82/201582/2015 Dear CommissioneMM I write on behalf of my client - . I sent you a letter on May 4, 2015 (and an amended letter a few
Page: EFTA00029457 →Sex Trafficking by Jeffrey Epstein and Ghislaine Maxwell Ref: AC/SCO/82/201582/2015 Dear CommissioneMM
Page: EFTA00029457 →ernational Sex Trafficking by Jeffrey Epstein and Ghislaine Maxwell Ref: AC/SCO/82/201582/2015 Dear Commiss
Page: EFTA00029457 →ill S.J. QUINNEY COLLEGE OF LAW m THE UNIVERSITY OF UTAH July 31, 2015 Assistant Commissioner Specialist Crime and Operations PAUL G. CASSELL Ronald N. Boyce Presidential Professor of Criminal Law Telephone: 801-585-5202 [email protected] New Scotland Yard London SW1H 0BG Re: International Sex Tr
Page: EFTA00029457 →gdom PAUL G. CASSELL Ronald N. Boyce Presidential Professor of Criminal Law May 4, 2015 Re: International Sex Trafficking by Jeffrey Epstein and Ghislaine Maxwell Dear Metropolitan Police: I write on behalf of my client — . She is the victim of an international sex trafficking crime in London shortly before
slaine Maxwell to be a "masseuse" for Jeffrey Epstein. Epstein was a billionaire with a mansion in the area. When went to the mansion, Epstein (and Maxwell) sexually abused her. was 15 at the time of the first sexual abuse. She became Epstein's "sex slave" over the next few years, and Epstein and Maxw
ernational Sex Trafficking by Jeffrey Epstein and Ghislaine Maxwell Dear Metropolitan Police: I write on be
GE OF LAW TI IC UNIVERSITY OF UTAH Metropolitan Police Service New Scotland Yard 8-10 Broadway London SW1H 0BG United Kingdom PAUL G. CASSELL Ronald N. Boyce Presidential Professor of Criminal Law May 4, 2015 Re: International Sex Trafficking by Jeffrey Epstein and Ghislaine Maxwell Dear Metropolitan P
a?) and (b) whether that recusal extends to others potential co-conspirators who may have performed acts in the Southern District of Florida — i.e., Ghislaine Maxwell. Thank you in advance for your assistance on these two issues. We have many other issues we wish to discuss with you on Thursday. Sincerely, Paul
he Southern District of Florida — i.e., Ghislaine Maxwell. Thank you in advance for your assistance on the
acts in the Southern District of Florida — i.e., Ghislaine Maxwell. Thank you in advance for your assistanc
ther issues we wish to discuss with you on Thursday. Sincerely, Paul Cassell and Brad Edwards for Jane Doe #3(and other victims) Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.J. Ouinnev College of Law at the University of Utah CONFIDENTIAL: This electronic message - along with any
dwards and Cassell identified by name in the Joinder Motion as having had sexual relations with were Prince Andrew, Duke of York ("Prince Andrew"); Ghislaine Maxwell ("Maxwell"); and Jean Luc Brunel ("Brunel") — all of whom had previously been identified by name by in media interviews. The Joinder Motion's alle
entified by name in the Joinder Motion as having had sexual relations with were Prince Andrew, Duke of York ("Prince Andrew"); Ghislaine Maxwell ("Maxwell"); and Jean Luc Brunel ("Brunel") — all of whom had previously been identified by name by in media interviews. The Joinder Motion's allegations abo
re Prince Andrew, Duke of York ("Prince Andrew"); Ghislaine Maxwell ("Maxwell"); and Jean Luc Brunel ("Brune
tions to tell her side of the story. Could you call me quickly about Nightline or related possibilities? Paul Cassell 801-xxx-xxxx Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah This email thus repeats the false allegation that Ders
TINE To: Miami From: Miami PB-1, Palm Beach County Contact: SA II Approved By: Drafted By: Case ID #: 31E-FM-108062/ Title: JEFFREY EPSTEIN; GHISLAINE MAXWELL; WSTA - CHILD PROSTITUTION Attn: RA Date: 01/08/2010 Synopsis: To request transfer of above captioned case due to agent's transfer to another s
odeling agency. According to a complaint filed in the U.S. District Court for the Southern District of Florida, en alleged victim said that Epstein, Maxwell, and 'deliberately engaged in a pattem of racketeering that involved luring minor children through MC2, mostly girls under the age of 17, to engag
ed newspaper baron Robert Maxwell, that gives most concern. He was first seen with the pair on holiday in Thailand, and was pictured cavorting with Ghislaine at a Halloween fetishthemed party in Manhattan. The photograph that appeared last weekend shows the prince strolling through Central Park with 58-
H March 1, 2011 Wifredo A. Ferrer United States Attorney Southern District of Florida 99 N.E.4th Street Miami, FL 33132 • • PAUL. G. CASSELL Ronald N. Boyce Presidential Professor of Criminal Law Telephone: 801-585-5202 [email protected] Re: Jane Doe #1 and Jane Doe #2 vs. United States, No. 09-80
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t the federal government does not intervene in sex-assault cases, except if we're deal- ing with a serial rapist or it crosses jurisdictional lines," Maxwell said. "It's either not a big enough case or not atrocious enough for them." Epstein, 56, served 13 months of his 18-month sentence at the Palm Beac
ivied In favor of two crime deigns represented by Farmer. fats Wafting. Edwards Filet Lehrman Partner Brad Edwards and he co-coansel Paul Cassell. Ronald N. Boyce Presidential Pf0105$01 of Criminal Law - S.J. aumney Col ego of Low al the Unisersity of Utah. The ruling uphold the Darnel Court wrath ordered the
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
Page: HOUSE_OVERSIGHT_015531 →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
Page: HOUSE_OVERSIGHT_015532 →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,
Page: HOUSE_OVERSIGHT_015538 →EXHIBIT 4 HOUSE_OVERSIGHT_016197 --- PAGE BREAK --- Case 1:19-cv-03377-LAP Document 36-4 Filed 07/03/19 PAUL G. CASSELL Ronald N. Boyce Presidential! Professor of Criminal Law THE UNIVERSITY OF UTAH and University Distinguished Professor of Law S.J. QUINNEY Telephone: 801-585-5202 -
Page: HOUSE_OVERSIGHT_016198 →vidence I possessed showed the following things. 36. On February 9, 1998, Alan Dershowitz appears on flight #1073 to Teterboro Airport with Epstein, Ghislaine Maxwell, Emmy Taylor, Claire Hazel, Joel Pashcow, one unidentified female, Mandy and Dubins +1 (without his wife). 37. On February 5, 2004, Alan Dershowitz
Page: HOUSE_OVERSIGHT_016200 →n flight #1073 to Teterboro Airport with Epstein, Ghislaine Maxwell, Emmy Taylor, Claire Hazel, Joel Pashcow,
Page: HOUSE_OVERSIGHT_016200 →e course of professional dealings with them, including working closely with them as co-counsel to represent Ms. Giuffre in the complicated Giuffre v. Maxwell case. At all times they have exhibited nothing but the highest levels of professionalism and adherence to cthical requirements. 54, I expected no le
Page: HOUSE_OVERSIGHT_016201 →Entities connected to both Ghislaine Maxwell and Ronald N. Boyce

Jeffrey Epstein
PERSON
Prince Andrew
PERSONSouthern District
LOCATION
United States
LOCATION
George W. Bush
PERSON
Bradley Edwards
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Department of Justice
ORGANIZATION
FedEx
ORGANIZATION
Marc Rich
PERSON
Donald Trump
PERSONLeon Black
PERSONthe Southern District
LOCATION
Eric Trump
PERSONJane Doe
PERSONDarren Indyke
PERSON
Virginia Giuffre
PERSONMaria Farmer
PERSON
New York
LOCATION