Epstein Secrets

Denver. Colorado 80203 PH 303.831.7364 rx 303.832.2628 www.hmflaw.corn Imenningerathmflaw.com v. Darren K Indyke, et aL On behalf of defendant Ghislaine Maxwell, I write under Judge Schofield's Individual Rules and Procedures for Civil Cases III(A)(1) and this Court's Practices II(A) to request a pre-motion

articipate in the Program and accept payment will be required to release all former employees or potential indemnitees of the Estate, including Ms. Maxwell, from any and all claims or causes of action that concern acts of sexual abuse by Mr. Epstein. We understand that, if the Program is approved, it ma

v. Darren K Indyke, et aL On behalf of defendant Ghislaine Maxwell, I write under Judge Schofield's Individ

2 of 3 Hon. Debra Freeman May 13, 2020 Page 2 Ms. Maxwell has asserted her plan to undertake a vast, broa

epeatedly announced its "ongoing" criminal investigation into alleged Epstein "co-conspirators" on the same topic as Plaintiff alleges in this case. Kashi v. Gratsos, 790 F.2d 1050, 1057 (2d Cir.1986) (citing SEC v. Dresser Industries, 628 F.2d 1368, 1375 (D.C.Cir.) (en banc), cert. denied, 449 U.S. 9

s%st:Nabl'AgeRMit ebc4R9d21127P, 41M5§03.13arlis§g4 iea 7 App.-0132 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, V. Ghislaine Maxwell, Defendant. X 15-cv-07433-RWS Motion to Compel Plaintiff to Disclose Alleged "On-going Criminal Investigations by Law Enforcement [sic!" or, In

S. Pagliuca GAN, AND FOREMAN, P.C. EFTA00097352 Cgsfist:i§:4-13-1UPSCRCieSt MAR T; 21Wp, Aia5i441111141P1PfiO4 e& 7 App.-0133 INTRODUCTION Ms. Maxwell, through counsel, requests, pursuant to Rules 37( a) and 26(c) of the Federal Rules of Civil Procedure that the Court enter an order requiring Plain

SOUTHERN DISTRICT OF NEW YORK X Plaintiff, V. Ghislaine Maxwell, Defendant. X 15-cv-07433-RWS Motion

5i441111141P1PfiO4 e& 7 App.-0133 INTRODUCTION Ms. Maxwell, through counsel, requests, pursuant to Rules 37(

defer [ ] civil proceedings pending the completion of parallel criminal prosecutions when the interests of justice seem[ ] to require such action"); Kashi v. Gratsos, 790 F.2d 1050, 1057 (2d Cir. 1986) ("IA] court may decide in its discretion to stay civil proceedings when the interests of justice see

s. Boeing Enter- prises executives say, include mart, aging the installation of aircraft into- . rpID o f ncgo ms op; en xi s ft tale NT 000262 GM _00005045 _ EFTA_00119118 EFTA01265757 Ard7SZAfC Boeing Commercial Airplane Group Public Paean P.O. Box 3707, MS 65-47 &same, WA 98t24-2207

Mr. Jeffrey Epstein J. Epstein and Company, Inc. The Villard House 457 Madison Avenue New York, NY 10022 Dear Jeffrey: I have talked to you and Ghislaine on several occasions to say thank you. But, I wanted to express in writing my personal and professional gratitude for the very generous gift . $20

closure CONFIDENTIAL INT 000219 SONY_GM_00005002 EFTA_00119075 EFTA01265714 Interlochen Center for the Arts 0 Interlochen December 23, 1994 Ghislaine Maxwell 4 1imislinsiejn CrimnAnv hard house 457 Madison Avenue New York, NY 10022 Dear Ghislaine: Enclosed is the envelope we recently found in cleani

Arts 0 Interlochen December 23, 1994 Ghislaine Maxwell 4 1imislinsiejn CrimnAnv hard house 457 Madis

teresting alumni. One t written up in the NY ouse downtown ($41m?). One of your present studen .aughter of the people that own the co that makes Kashi (cereal) in LaJolla. I don't know the students name, but she is a sophmore (Elizabeth Brown's age) and loves IAA. She is a creative writer, and her

Arts 0 Interlochen February 9, 1994 Mr. Jeffrey Epstein J. Epstein and Company, Inc. New York, NY 10022 Dear Jeffrey: I have talked to you and Ghislaine on several occasions to say thank you. But, I wanted to express in writing my personal and professional gratitude for the very generous gift $20

nt Institutional Advancement Enclosure CONFIDENTIAL INT 000219 EFTA00102920 Interlochen Center for the Arts 0 Interlochen December 23, 1994 Ghislaine Maxwell c/o J. ' rnmnanv Inc * New York, NY 1002 Dear Ghislaine: Enclosed is the envelope we recently found in cleaning the Epstein Lodge. Apparently i

Arts 0 Interlochen December 23, 1994 Ghislaine Maxwell c/o J. ' rnmnanv Inc * New York, NY 1002 Dear

teresting alumni. One t written up in the NY ouse downtown ($41m?). One of your present studen •aughter of the people that own the co that makes Kashi (cereal) in LaJolla. I don't know the students name, but she is a sophmore ( age) and loves IAA. She is a creative writer, and her parents were at

imited purpose of seeking a stay of the action, and (2) stay this matter in its entirety pending the resolution of the criminal prosecution against Ghislaine Maxwell in the matter of United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN). As discussed below, the Government submits that a complete stay of this civil

nt submits that a complete stay of this civil action will serve the public interest of preserving the integrity of the criminal prosecution against Maxwell and will conserve private, public, and judicial resources; and that those interests will outweigh any delay or disruption caused to the resolution o

stay civil cases in the interests of justice pending the completion of criminal prosecution. See Landis v. North Am. Co., 299 U.S. 248, 255 (1936); Kashi v. Gratsos, 790 F.2d 1050, 1057 (2d Cir. 1986). Courts routinely grant applications to stay civil proceedings in order to protect a pending crimina

Judge Nathan held that Maxwell is not entitled to know who the Government's trial witnesses are at this stage of the criminal case. United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN), Dkt. 49. Consistent with that ruling, the Government is not including detailed information in this letter about who thos