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United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. I PLAINTIFF REPLY IN SUPPORT OF MOTION TO PRESENT TESTIMONY FROM JEFFREY EPSTEIN FOR PURPOSES OF OBTAINING AN ADVERSE INFERENCE INS
Sent Wednesday, January 21, 2015 4.47 PM To: G Maxwell Subject FW Guardian This will now end but I th
mail.com, Sent Thursday, January 15, 2015 5:27 PM To: Gmax do you want shwIly to come out and say she was the girlfriend , during the time . be GM 01081. Or this email, in which Epstein urges Defendant to send a dismissive press statement: 2 As the Court will recall from earlier proceedings in
" See Plaintiffs' Response to Defendant's Motion for Summary Judgment at 7. explained that when Defendant called, she would just say: "Hi. This is Ghislaine. Jeffrey was wondering if you had anybody that could come over." Id. And there is significant related evidence collected in the summary judgment mo
March 9th, 2001, you, the Defendant in this case, Ms. Maxwell, Emmie M, and ] flew on your private jet from
not produced) about how to best coordinate a response to the allegations. For example, Epstein had enough of a dog in this fight to offer to have "Shelley" come forward to lie and pretend to have been his girlfriend during the time he and Defendant were trafficking And even today, Defendant Epstein c
ers, The Chiropractor ICleaners Creative Custom Swim- Devito, Dawn Driver - PB Epstein, Jeffrey 58 El Bnlo Wa EFTA00183030 212308 0519 °mem Maxwell, Ghislaine 58 El 8n1/0 Way Beach. Fkaida 33480 Ike Pezulo I 130No hbor e ogens, Larry Pompano Helicopter Vet MIcheetraell— RANCH (RH) tovek
Chiropractor ICleaners Creative Custom Swim- Devito, Dawn Driver - PB Epstein, Jeffrey 58 El Bnlo Wa EFTA00183030 212308 0519 °mem Maxwell, Ghislaine 58 El 8n1/0 Way Beach. Fkaida 33480 Ike Pezulo I 130No hbor e ogens, Larry Pompano Helicopter Vet MIcheetraell— RANCH (RH) tovek2. Bodie Jo
Stank) . NM 97056 Kelly. John Kerney. Ga ardson. Bill eisBruca, Santa Fe Institute King, Rhonda - New Mexico Singleton, Dr. & Mrs. RM bolt Shelley EFTA00183032 FM< FrPPltnari Grumbridge, Malcolm LomaMe, Pierre Marden Scott and Sarah Nitrcr. Marden Scott and Sarah Nurse Marden, Scott &
ushed and cleaned, garden hose organizer needs to be installed, vinyl floor on bottom landing and cove base needs to be replaced. ■ Remove all of GM,s Madison avenue office and 727 plane storage items, furniture ,windows ,all storage from catering kitchen area to put kitchen back in service. ■
and Rich perform for her EFTA00304475 17. Air Ghislaine - owned by GM - should we change this? Sound and
rs to re-arrange furniture 5. put up scaffolding in living room to paint ceiling *Week of June 22nd 6. Will get marble finishes for entry office - Shelley went to the place JE and Sarah suggested in NYC but they discontinued that stock so Shelley ordered it from Paris and it will be here next week. Sh
: at 71st 9:30am: meeting with Dangene at 629 Park Ave 11:15am: Rich Khan and Harry 12:30pm: 12:30pm Leon Black for lunch 2pm: Jes Staley 3pm: GM 5pm: Robert Couturier and Shelley EFTA_R1_0 1493846 EFTA02425499
th Dangene at 629 Park Ave 11:15am: Rich Khan and Harry 12:30pm: 12:30pm Leon Black for lunch 2pm: Jes Staley 3pm: GM 5pm: Robert Couturier and Shelley EFTA_R1_0 1493846 EFTA02425499
Entities connected to both Ghislaine Maxwell and Shelley

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
United States
LOCATION
George W. Bush
PERSON
NEW YORK NY
LOCATION
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Michael Cohen
PERSON
Marc Rich
PERSON
Donald Trump
PERSONLeon Black
PERSON
Bradley Edwards
PERSON
Eric Trump
PERSON
Julie K. Brown
PERSONDarren Indyke
PERSON
Virginia Giuffre
PERSONMaria Farmer
PERSON
Denver
LOCATIONEmmy Taylor
PERSON
Joi Ito
PERSON