Epstein Secrets

s Unit From: Bogota Contact: ALAT Approved By: Drafted By: I )-1 4) Attn SA : Case ID #: 31E-MM-108062 Title: JEFFREY EPSTEIN; (Pending) GHISLAINE MAXWELL; WSTA - CHILD PROSTITUTION Synopsis: Victim provided with USAO letter. Enclosure: Colombian Departamento Administrativo (DAS) report 1- 2007- 679

mi From: Canberra Sydney Sub-Office Contact: ALAT Approved Sy: Drafted By: Case ID # 31E-MM-108062 Title: JEFFREY EPSTEIN; • (Pending) -ove GHISLAINE MAXWELL; WSTA - CHILD PROSTITUTION Synopsis: Lead set to Legat Canberra covered by the Sydney Sub Office. Reference: 31E-MM-108062 Serial 174 En

Canberra Sydney Sub-Office Contact: ALAT Approved Sy: Drafted By: Case ID # 31E-MM-108062 Title: JEFFREY EPSTEIN; • (Pending) -ove GHISLAINE MAXWELL; WSTA - CHILD PROSTITUTION Synopsis: Lead set to Legat Canberra covered by the Sydney Sub Office. Reference: 31E-MM-108062 Serial 174 Enclosure(

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te of limitations has expired for the woman's case criminally and civilly, and will almost certainly be Character: or 3IE-MM-108062 Submitting Dillon: Indexing dismissed. He refused to comment on Epstein's Floridaha es Meanwhile. also acknowledg tat is client was living with him and was at

Case 1:15-cv-07433-RWS Document 25 Filed 12/28/15 Page 1 of 13 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK Plaintiff, Ghislaine Maxwell, Defendant. Case No.: I5-cv-07433-RWS REPLY MEMORANDUM OF LAW IN SUPPORT OF DEFENDANT'S MOTION TO DISMISS COMPLAINT Laura A. Menninger HADDON,

INTRODUCTION ARGUMENT I. PLAINTIFF FAILED TO PLAUSIBLY PLEAD DEFAMATION A. Plaintiff Failed to Adequately Plead a Defamation Claim 1 B. Ms. Maxwell's Statement In Context Is Not Defamatory 3 II. MS. MAXWELL'S STATEMENTS ARE PROTECTED BY PRIVILEGE 6 A. Qualified Privilege May Form the Basis f

OR THE SOUTHERN DISTRICT OF NEW YORK Plaintiff, Ghislaine Maxwell, Defendant. Case No.: I5-cv-07433-RWS

ed to Adequately Plead a Defamation Claim 1 B. Ms. Maxwell's Statement In Context Is Not Defamatory 3 II.

ss statements, giving all the particulars of their origination," (Pl.'s Opp'n at 19), the Complaint shows otherwise. This alone warrants dismissal. Dillon, 261 A.D.2d at 39-40 (dismissing defamation claim absent entire subject statement, noting "the defect is all the more curious in that [plaintiff] co

/15 Page 1 of 29 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X PLAINTIFF, V. GHISLAINE MAXWELL, DEFENDANT. X 15-cv-07433-RWS GHISLAINE MAXWELL'S MEMORANDUM OF LAW IN SUPPORT OF MOTION TO DISMISS COMPLAINT Laura A. Menninger, Esq. HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Ave

r CO 80203 Tel: Dated: November 30, 2015 EFTA00595583 Case 1:15-cv-07433-RWS Document 15 Filed 12/01/15 Page 2 of 29 Table of Contents I. MS. MAXWELL'S STATEMENTS ARE PRIVILEGED 9 A. The Self-Defense Privilege Protects Ms. Maxwell's Statements 9 B. The Pre-Litigation Privilege Protects Ms. Maxw

attributed statement responds directly to allegations and claims made by Plaintiff. Compl. 1 31. Likewise to the extent the claimed statement that "Ghislaine Maxwell's original response to the lies and defamatory claims remains the same" (Compl. 1 32) refers to an earlier statement describing Plaintiff's "factual

led 12/01/15 Page 2 of 29 Table of Contents I. MS. MAXWELL'S STATEMENTS ARE PRIVILEGED 9 A. The Self-Defen

Merrill Lynch & Co., 1995 US Dist. LEXIS 10017 (S.D.N.Y. 1995) 13 Deutsche Asset Mgmt, Inc. v. Callaghan, No. 01 Civ 4426 CBM, 2004 WL 758303 16 Dillon v. City of New York, 704 N.Y.S.2d 1, 5 (1st Dep't 1999) 8,18 Edwards v. Great Northern Ins. Co., No. 03 CV 2947 (NG) (RML), 2006 WL 2053717, (E.D.

tment of Business and Professional Regulation by Gov. Ron DeSantis in 2019; Pirozzolo became a medical marijuana entrepreneur and GOP fundraiser." Maxwell Pleads Not Guilty To Sex Trafficking Charges. EFTA00149771 Bloomberg (4/23, Hurtado, Vohs, 3.57M) reports "British socialite" Ghislaine Maxwell on

undraiser." Maxwell Pleads Not Guilty To Sex Trafficking Charges. EFTA00149771 Bloomberg (4/23, Hurtado, Vohs, 3.57M) reports "British socialite" Ghislaine Maxwell on Friday pleaded not guilty to new sex trafficking charges, her first public comments "since her arrest last July on sex crimes charges stemming f

Hurtado, Vohs, 3.57M) reports "British socialite" Ghislaine Maxwell on Friday pleaded not guilty to new sex

ical campaigns anonymously." Trump Organization CFO Says "Legal Side" Of Money Flow Is "Not My Thing." The New York Daily News (4/25, Crane-Newman, Dillon, 2.51M) reports Trump Organization CFO Allen Weisselberg, who is "now in the crosshairs of prosecutors diving into Donald Trump's business dealings

ersity's Center for Security Studies," and David Maxwell, a "former US Special Forces officer and North Ko

Organization, and Sheri A. Dillon, who has represented President Trump and his company on tax matters. The office also asked the judge to order Ms. Dillon's firm — Morgan, Lewis & Bockius — to comply with a subpoena, along with the Trump Organization, two related entities that own Trump properties, and

ersity's Center for Security Studies," and David Maxwell, a "former US Special Forces officer and North K

Organization, and Sheri A. Dillon, who has represented President Trump and his company on tax matters. The office also asked the judge to order Ms. Dillon's firm - Morgan, Lewis & Bockius - to comply with a subpoena, along with the Trump Organization, two related entities that own Trump properties, and

ins Lashing Jamaica as 'Catastrophic' Category 5 Storm • China Pushes to Silence Victims of African Mining Disaster • Prince Andrew Hosted Epstein, Maxwell and Weinstein at Royal Lodge • The 92-Year-Old President Who Never Loses • Iranian Women Flout Law on Mandatory Veiling as Police Curtail Arrests

rch, and his attorneys plan to challenge parts of the grand jury process. Additional reporting was provided by the Las Vegas Review- Journal (10/27, Dillon). Second Circuit Upholds Keith Raniere Sex Cult Abuse Conviction Courthouse News Service (10/27, Stapley) reported that the Second Circuit Court of

ed arguments that purely intrastate conduct could not be prosecuted under the federal Child Pornography Prevention Act of 1996 ("CPPA"). First, in Maxwell, we held that 18 U.S.C. § 2252A(a)(5)(B) was not unconstitutional as applied to a defen- dant's intrastate possession of child por- nography, even

tifying the person intended to be bound, and not effective as against another who might succeed to the office upon his death or resignation. See Dillon on Municipal Corporations, vol. 4 (5th Ed.) Sec. 1536. The injunction restrains McElligott, his agents, servants, subordinates, and employes, `

ersity's Center for Security Studies," and David Maxwell, a "former US Special Forces officer and North K

Organization, and Sheri A. Dillon, who has represented President Trump and his company on tax matters. The office also asked the judge to order Ms. Dillon's firm - Morgan, Lewis & Bockius - to comply with a subpoena, along with the Trump Organization, two related entities that own Trump properties, and

e the charges against him were pending. OA (citing United States v. Epstein 19 Cr. 490 (RMB), Nolle Prosequi (Dkt. No. 52))) B. The Prosecution of Ghislaine Maxwell On June 29, 2020, Ghislaine Maxwell was indicted by a grand jury in this District on "one count of conspiracy to entice minors to travel to engage

Prosequi (Dkt. No. 52))) B. The Prosecution of Ghislaine Maxwell On June 29, 2020, Ghislaine Maxwell was

ntent to engage in criminal sexual activity"; "and two counts of perjury." (Third Comey Decl. (Dkt. No. 59) 1 6) On December 29, 2021, a jury found Maxwell guilty of enticing a minor to travel to engage in illegal sex acts, transporting minors with the intent to engage in criminal sexual activity, and

would result from disclosure, the FBI notes that "the Maxwell criminal prosecution is still pending on appeal,