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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
Link ; Jeff Monday is Veteran's Day and I have a number of things already scheduled. Tuesday I'm in a mediation all day and Wednesday we have Mr. Zinoviev's deposition scheduled (pending Scott's trial calendar). Because of my tight schedule, please just let me know what your concerns are in writing and
t to New York. Q And when was the first time you went to Now York? A In 2006. Q 2006. And was the reason you went to New York in 2006 for Ms. Maxwell's party? A No. It was III I think had a surgery. Q Okay. And you were there to cover fur her while she had surgery? A Yes. Q And how long we
talking about a time period where you worked one day and then the following day you came in in the afternoon because you had received a call from Ghislaine Maxwell. Do you remember that scenario? A Yes. Q When you received the call from Ghislaine Maxwell, you didn't know at that time that the police had ev
e afternoon because you had received a call from Ghislaine Maxwell. Do you remember that scenario? A Yes.
was the reason you went to New York in 2006 for Ms. Maxwell's party? A No. It was III I think had a surgery
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 A Yes. Q And what is Igor's last name, do you know? A I don't know. Q Does Zinoviev sound familiar? A Because sometimes they called him Igor Z. Q Igor "Z," is that what you're saying? Yes? Igor then the letter "Z"? A Yes. Q
over up what needs to be brought to light. Jeffrey is no longer here, and the women that helped him are, Ghislaine Maxwell. My experience is with Ghislaine Maxwell and Sarah Kellen, and they definitely need to be held accountable for helping him, helping themselves, helping one another carry on this huge, almo
aking this morning is Sarah Ransome. MS. RANSOME: Thank you, your Honor. My name is Sarah Ransome, R-a-n-s-o-m-e. I'm a victim of Jeffrey Epstein and Ghislaine Maxwell's international sex trafficking ring. I would like to thank the Court for the dignity and the respect you are showing me here today, as well as the oth
by Ghislaine Maxwell. Upon my first meeting of her, I wouldn't know I had been recruited until many years later, when I would read it in a headline. Ghislaine and Jeffrey took me in. They sent me to school. They gave me a job. They flew me around the world, introduced me to a world I SOUTHERN DISTRICT REPOR
s beau was a CIA spook, a math teacher, a concert pianist or a corporate headhunter. "But what is the truth about him?” the newspaper wondered. “Like Maxwell, Epstein is both flamboyant and intensely private.’’ The media frenzy did not begin in full until a decade later. In September 2002, Epstein was flun
r, celebrity bodygµard ;3.n,dmoyie stuptqian, according to the league's Web sit!:!. The:NewJersey resident visited Epstein sE:!ven times in July. Zinoviev, Scharik and Marcinkova could not be reached for comm~nt. Staffresearch~r Niels Hdme:riks cQntr1butE:!d; to this story. FILED: PALM BEACH COUNTY,
he background as he navigated New York high society. When he first attracted notice in the early 1990s, it was on account of the woman he was dating: Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell. In a lengthy article, headlined "The Mystery of Ghislaine Maxwell’s Secret Love,” the Brit
s beau was a CIA spook, a math teacher, a concert pianist or a corporate headhunter, "But what is the truth about him?” the newspaper wondered. "Like Maxwell, Epstein is both flamboyant and intensely private.” The media frenzy did not begin in full until a decade later. In September 2002, Epstein was flung
0s, it was on account of the woman he was dating: Ghislaine Maxwell, daughter of the late British media tycoo
nal trainer,, celebrity bodyguard and movie stuntman, according to the league’s Web site, The NewJersey resident visited Epstein seven times in July. Zinoviev, Schank and Marcinkova could not be reached for comment, Staff researcher Niels Heimeriks. contributed to this stoty: CA/Aronberg-000184 FILED: PALM
background as he navigated New York high society. When he first attracted notice in the early 1990s, it was on account of the woman he was dating: Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell. In a lengthy article, headlined "The Mystery of Ghislaine Maxwell's Secret Love," the Bri
beau was a CIA spook, a math teacher, a concert pianist or a corporate headhunter. "But what is the truth about him?" the newspaper wondered. "Like Maxwell, Epstein is both flamboyant and intensely private." The media frenzy did not begin in full until a decade later. In September 2002, Epstein was fl
s, it was on account of the woman he was dating: Ghislaine Maxwell, daughter of the late British media tycoo
trainer, celebrity bodyguard and movie stuntman, according to the league's Web site. The New Jersey resident visited Epstein seven times injuly. Zinoviev, Schank and Marcinkova could not be reached for comment. Staff researcher Niels Heimeriks contributed to this story. NOT A CERTIFIED COPY Palm B
3,832.50 1.40 196.00 7.60 3,990.00 1.60 224.00 4.80 2,520.00 4.00 1,140.00 10.00 5,250.00 8.50 2,422.50 9.50 4,987.50 EFTA00794324 Ghislaine Maxwell Statement Date: Account No. 2592.000 Statement No. Re: v. Epstein, et al. Page No. 11/30/2018 3102 2 Hours 11/09/2018 LAM Email correspon
,422.50 9.50 4,987.50 EFTA00794324 Ghislaine Maxwell Statement Date: Account No. 2592.000 Statement
0 8.50 2,422.50 9.50 4,987.50 EFTA00794324 Ghislaine Maxwell Statement Date: Account No. 2592.000 S
/2018 3102 2 Hours 11/09/2018 LAM Email correspondence with counsel re. Igor depo (multiple) 0.30 157.50 11/12/2018 AW Review documents re: Zinoviev; prepare deposition materials for L. Menninger. 1.90 266.00 LAM Email correspondence with counsel re. depo schedule 0.40 210.00 11/13/2018 AW
ront 215:12 frontal 149:7 furnished 218:9 further 214:17 217:9 217:11 G 135:1 gardener 186:21 193:14 getting 141:6,10 200:24 215:10 Ghislaine 195:11,14,25 196:9,14 198:19 199:9,13 200:8 201:10,15 girl 149:25 151:17,23 152:10 160:15 182:24 192:23 girls 159:17 167:14 204:20
2:2 203:12 206:23 massaging 158:2 masseuses 204:23 master 211:19 material. 158:13 204:14 materials 154:8 matter 136:19 178:24 218:7 Maxwell 145:17 184:7 184:9,12,19 184:20 185:7,14 193:19 195:11,14 195:25 196:9,14 198:19 199:3,9,13 200:8 201:10,15 209:16,17 209:21,24 210:17
8,11 165:12 166:10,12 166:18 167:6,8,12 167:14,18 167:20 168:8 169:8 202:15,18 203:6 205:25 207:4,18 young-loo. 205:11 z 172:5,6,7,23 Zinoviev 172:4 $2,000 141:24 $42,000 140:15 $5,000 140:17,23 141:14 $500 142:7,8 _8 1118991 131:22 132:22 04 0 177:20 179:7 179:14,15 180:4,
Entities connected to both Ghislaine Maxwell and Zinoviev

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
JPMorgan Chase
ORGANIZATION
United States
LOCATION
George W. Bush
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Marc Rich
PERSON
Donald Trump
PERSONLeon Black
PERSON
Bradley Edwards
PERSON
Virginia Giuffre
PERSON
New York
LOCATIONMaria Farmer
PERSON
Les Wexner
PERSONJane Doe
PERSON
Joe Biden
PERSON
Lesley Groff
PERSON
Prince Charles
PERSON
New York City
LOCATION