Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL Defendant. X 15-cv-07433-RWS DEFENDANT'S REPLY IN SUPPORT OF MOTION IN LIMINE TO EXCLUDE IN TOTO CERTAIN DEPOSITIONS DESIGNATED BY PLAIN

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL Defendant. X 15-cv-07433-RWS DEFENDANT'S REPLY IN SUPPORT OF MOTION IN LIMINE TO EXCLUDE IN TOTO CERTAIN DEPOSITIONS DESIGNATED BY PLAINTIFF FOR

Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 EFTA00595612 Defendant Ghislaine Maxwell ("Ms. Maxwell") files her Reply in Support of the Motion in Limine to Exclude In Toto certain depositions designated by Plaintiff for use at trial a

203 EFTA00595612 Defendant Ghislaine Maxwell ("Ms. Maxwell") files her Reply in Support of the Motion in Li

trial. She has now obtained an agreement to accept service by Mr. Epstein's counsel, mooting any claim that he is unavailable.' With respect to Mr. Rizzo, she concedes he resides within 100 miles of the courthouse, and provides no basis to claim that he cannot be served. Based on these confessions, th

ow 9 C. Jean Luc Brunel 10 D. Jeffrey Epstein 12 E. and 14 II. FIFTH AMENDMENT BY EPSTEIN, OR NOT ADMISSIBLE IN THIS CASE AGAINST MS. MAXWELL 15 III. PLAINTIFF'S BAD FAITH DISCOVERY TACTICS SHOULD NOT BE REWARDED WITH EXTRA TIME 18 1. Plaintiff's Rule 26 Revolving Door 18 2. Plainti

, 2014 WL 4354691, at *15 (S.D.N.Y. Sept. 2, 2014) 20 ii EFTA00605114 Case 1:15-cv-07433-RWS Document 228 Filed 06/20/16 Page 4 of 29 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Combined Response ("Response") in Opposition to Plaintiff's Motion to Extend Deadline to Complete Depositions ("Motion")

SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL. Defendant. X 15-cv-07433-RWS DEFENDA

PSTEIN, OR NOT ADMISSIBLE IN THIS CASE AGAINST MS. MAXWELL 15 III. PLAINTIFF'S BAD FAITH DISCOVERY TACTIC

that witness Rinaldo Rizzo had a deposition re-scheduled from April until June does not have any bearing on the issue presented by this motion. Mr. Rizzo was deposed on June 14 and he has nothing to do with the remaining depositions. Mr. Rizzo, in fact, was practically gleeful to be a witness: Doc.

f Epstein; b) Attorney Bruce Reinhart's involvement in and/or awareness of the Government's • • witness, subject, or t ' investigation, includin Ghislaine Maxwell, Lesley Groff, Larry Morrison, Larry Visoki, David Rogers, William Hammond, and Robert Roxburgh; c) All documents, correspondence, and other info

ubject, or t ' investigation, includin Ghislaine Maxwell, Lesley Groff, Larry Morrison, Larry Visoki, Da

witness, subject, or t ' investigation, includin Ghislaine Maxwell, Lesley Groff, Larry Morrison, Larry Vi

ion against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr

that the FBI's inaction led to Epstein abusing scores of women and girls. The article noted that Farmer says she flagged Epstein and his accomplice Ghislaine Maxwell to New York cops and the feds in 1996 but says agents failed to take action. Public Confidence in the FBI Has Diminished by 15% In the Last Five Ye

she flagged Epstein and his accomplice Ghislaine Maxwell to New York cops and the feds in 1996 but says a

armer says she flagged Epstein and his accomplice Ghislaine Maxwell to New York cops and the feds in 1996 bu

ed himself as a girl in some of those communications. Those allegations are not explicitly referenced in his plea deal. The Washington Post (07/21, Rizzo), Los Angeles Times (07/21, Battaglio), Daily Beast (07/21, Bolies), Rolling Stone (07/21, Rawnsley), New York Post (07/21, DeGregory), and Business

iler, seeking big financial penalties, for the role its pharmacies may have played in the opioid crisis. (AP) • Jeffrey Epstein's' onetime partner, Ghislaine Maxwell, insisted in a newly unsealed 2016 deposition that she had no knowledge of the deceased financier having sexual contact with minors. Maxwell was c

slaine Maxwell, insisted in a newly unsealed 2016 deposition that she had no knowledge of the deceased financier having sexual contact with minors. Maxwell was charged earlier this year with trafficking minors in concert with Epstein and with lying under oath. (Rosalind Helderman, Shayna Jacobs, Beth

isis. (AP) • Jeffrey Epstein's' onetime partner, Ghislaine Maxwell, insisted in a newly unsealed 2016 depos

y claims during the debate. "Trump yet again broke the fact-check meter ... while [Biden] made relatively few gaffes," per Glenn Kessler, Salvador Rizzo and Meg Kelly. • "It came down to muting the president. That's what it took to stage a reasonably civil debate," writes critic-at-large Robin Givha

b) Attorney involvement in and/or awareness of the Government's interest in any witness, subject, or t et of the E stein invests ation includin Ghislaine Maxwell, , Louella Ruboyo, Larry Morrison, Larry Visold, David Rogers, William Hammond, and Robert Roxburgh; c) All documents, correspondence, and other i

of the E stein invests ation includin Ghislaine Maxwell, , Louella Ruboyo, Larry Morrison, Larry Visold,

, or t et of the E stein invests ation includin Ghislaine Maxwell, , Louella Ruboyo, Larry Morrison, Larry

ion against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr

the Government's witness, subject, or tar et o Ghislaine Maxwell, ▪ Investigation Includi Larry Mo iso

cution/non-prosecution of Epstein; b) Attorney Bruce Reinhart's involvement in and/or awareness of the Government's witness, subject, or tar et o Ghislaine Maxwell, ▪ Investigation Includi Larry Mo iso i 1 ogers, r lam Hammond, and Robert Roxburgh; c) All documents, correspondence, and other information r

nment's witness, subject, or tar et o Ghislaine Maxwell, ▪ Investigation Includi Larry Mo iso i 1 oge

ion against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr

n of Epstein. b) Attorney involvement in and/or awareness of the Government's n witness, subject, or tar et of the Epstein i including )111%1;6 Maxwell, Larry Morrison, iso , David Rogers, William Hammond, and Robert Roxburgh; c) All documents, correspondence, and other information reflecting tel

ion against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr