Epstein Secrets

018 at 6:34:54 PM EST To: | Subject: Press Inquiry: Miami Herald expose and protective order Dear Mr. Link: A transcript made public today show how Ghislaine Maxwell's legal team fought for and ultimately won a broad protective order in the lawsuit filed by accuser Sarah Ransome against your client Jeffrey Epstein.

for and ultimately won a broad protective order in the lawsuit filed by accuser Sarah Ransome against your client Jeffrey Epstein. It also shows the Maxwell legal team's concern about the media coverage, especially from the Miami Herald, weeks before it published today's bombshell investigation today. My

r. Link: A transcript made public today show how Ghislaine Maxwell's legal team fought for and ultimately wo

gainst your client Jeffrey Epstein. It also shows the Maxwell legal team's concern about the media coverage, es

From: Scott J. Link Sent: 11/28/2018 11:50:16 PM To: E. jeffrey [[email protected]] cc: Subject: Fwd: Press Inquiry: Miami Herald expose and protective order Im

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. No. 17 Civ. 00616 (JGK) JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROW and Defendants. PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANTS Plaintiff, by and through her undersign

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. No. 17 Civ. 00616 (JGK) JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROW and Defendants. PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANTS Plaintiff, by and through her undersigned couns

ies, e-mail, text, modem transmission, computer generated message, mail, personal delivery or otherwise. 3. "Defendants" shall mean the defendants Ghislaine Maxwell. Jeffrey Epstein. Lesley Groff, and 4. "Document" shall mean all written and graphic matter, however produced or reproduced, and each and every t

sel for Ghislaine Maxwell Michael Miller Justin Y.K Chu Michael A. Keough STEPTOE & JOHNSON LLP 1114 Avenue of the Americas New York, NY 10036 Scott J. Link LINK & ROCKENBACH, PA 1555 Palm Beach Lakes Boulevard Suite 930 West Palm Beach, FL 33401 Counsel for Jeffrey Epstein, and Lesley Groff By: /s

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. No. 17 Civ. 00616 (1OK) JEFFREY EPSTEIN, GHISLAINE MAXWELL, Y GROFF and Defendants. PLAINTIFF'S RE-NOTICE OF TAKING VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN PLEASE TAKE NOTICE THAT, pursuant to R

ACH PA Counsel for Jeffrey Epstein, and Lesley Groff Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. Counsel for Ghislaine Maxwell By: /s/ Sigrid McCawley Sigrid McCawley 3 EFTA00808196

. 17 Civ. 00616 (1OK) JEFFREY EPSTEIN, GHISLAINE MAXWELL, Y GROFF and Defendants. PLAINTIFF'S RE-NOTICE

OF WITNESS JEFFREY EPSTEIN via Email to the following counsel of record. Michael Miller Justin Y.K Chu Michael A. Keough STEPTOE & JOHNSON LLP Scott J. Link LINK & ROCKENBACH PA Counsel for Jeffrey Epstein, and Lesley Groff Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.

Attached please find our firm's billing statement for services rendered through January 31, 2019. This invoice is an expense for video services for G. Maxwell's deposition on November 18, 2018. Please do not hesitate to call me if you have ny questions regardin is bill. Thank you. Very t y ours, Scott J

s invoice is an expense for video services for G. Maxwell's deposition on November 18, 2018. Please do no

xwell's deposition on November 18, 2018. Please do not hesitate to call me if you have ny questions regardin is bill. Thank you. Very t y ours, Scott J. Link SJL/pvd Attachment cc: Darren Indyke w/attachment [email protected] EFTA00792330 Link & Rockenbach, PA 1555 Palm Beach Lakes Blvd. Suite 930 West

ourt of Appeal's controlling case of General Motors Corp v. McGee, 837 So. 2d 1010 (Fla. 4'h DCA 2002), Edwards is about to suffer the same fate as GM based on his Rule 1.280-noncompliant privilege log and the central issues to Edwards' lawsuit that the e-mails implicate. As the trial judge in the

vice List below on November 14, 2018, through the Court's e-filing portal pursuant to Florida Rule of Judicial Administration 2.516(b)(1). SIM By: Scott J. Link (FBN 602991) Kara Berard Rockenbach (FBN 44903 Counsel for Counter-Defendant Jeffrey Epstein 9 EFTA00794306 SERVICE LIST Jack Scarola Karen E

home and produced to the FBI by Rodriguez. That's the houseman. Same ruling as I made earlier with regard to that. Photograph depicting Roberts, Maxwell and Prince Andrew. MS. ROCKENBACH: No relevance to this action. It's prejudicial. THE COURT: Same argument, Mr. Scarola? MR. SCAROLA: Yes, sir.

1). LINK & ROCKENBACH, PA 1555 Palm Beach Lakes Boulevard, Suite 301 West Palm Beach, Florida 33401 (561) 727-3600; (561) 727-3601 [fax] By: /s/ Scott J. Link Scott J. Link (FBN 602991) Kara Berard Rockenbach (FBN 44903) Angela M. Many (FBN 26680) Primary: [email protected] Primary: Kara@linkrockla

urt of Appeal's controlling case of General Motors Corp v. McGee, 837 So. 2d 1010 (Fla. zPil DCA 2002), Edwards is about to suffer the same fate as GM based on his Rule 1.280-noncompliant privilege log and the central issues to Edwards' lawsuit that the e-mails implicate. As the trial judge in the

icial Administration 2.516(b)(1). LINK & ROCKENBACH, PA 1555 Palm Beach Lakes Boulevard, Suite 930 West Palm Beach, Florida 33401 [fax] By: Is/ Scott J. Link (FBN Kara Berard Rockenbach (FBN Primary: Primary: Secondary: Secondary: Counsel for Counter-Defendant Jeffrey Epstein 9 EFTA00808712 SERVI