Epstein Secrets

7433-RWS Document 189 Filed 06/06/16 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X INNIErt INIMINME, Plaintiff, v. GHISLATNE MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S RESPONSE IN OPPOSITION TO MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT Laura A. Menninger Jeffr

er Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. EFTA00097395 Case 1:15-cv-07433-RWS Document 189 Filed 06/06/16 Page 2 of 11 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Response in Opposition to Plaintiff's Motion to Exceed Presumptive Ten Deposition Limit, and states as follows: INTRODUC

9 Filed 06/06/16 Page 4 of 11 Plaintiff makes a bizarre argument that somehow this testimony can be used to create an adverse inference against Ms. Maxwell,2 despite the fact that Ms. Maxwell did not invoke the Fifth Amendment and she testified fully and answered every question posed to her with the only

cument 189 Filed 06/06/16 Page 2 of 11 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Response in Op

06/16 Page 2 of 11 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Response in Opposition to Plaintiff

sense because a "moving party must not only justify those depositions it wishes to take, but also the depositions it has already taken." Id. (citing Barrow v. Greenville Indep. Sch. Dist., 202 F.R.D. 480, 482 (N.D.Tex. 2001)). This rule is in place because "a party could indirectly circumvent the cap o

HE NEWS • Federal Prosecutors Release Details Of Ghislaine Maxwell's Arrest. PROTESTS • Trump Criticizes "

HE NEWS • Federal Prosecutors Release Details Of Ghislaine Maxwell's Arrest. PROTESTS • Trump Criticizes "Anti-Cop C

desk, a seemingly misguided effort to evade detection from law enforcement. Prosecutors in a new court filing today asking a federal judge to keep Maxwell, the former girlfriend and alleged co- conspirator of convicted sex offender Jeffrey Epstein, behind bars." CNN (7/13, Scannell, 83.16M) reports, "F

as refused to declare her financial situation and they have been unable to determine whether she has had a job in more than 30 years. They rejected Ms Maxwell's $5 million bail proposal, claiming that offering a $3.75m home in London as collateral was meaningless as it could not be seized by US authorities.

ot just incrementalism, but whole-scale reform." Progressive Groups Forming PAC To Support Police Defunding Advocates. EFTA00150562 The AP (7/13, Barrow) reports that "a coalition of progressive groups is forming a political action committee to back local candidates who want to redirect money away fr

rable Alison J. Nathan United States District Judge Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (MN) Dear Judge Nathan: The Government respectfully submits this letter motion to quash the defendant's Rule 17(c)(3) subpoena to-t

te cross-examination is impossible without understanding the complete terms of the agreement with the Epstein Fund, including the claims concerning Maxwell, as well as others." (Def. Mot. at 6). Materials are not relevant and admissible at trial, as required by Nixon, simply because they aid the defenda

New York, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (MN) Dear Judge Nathan:

the mark. Any statements in the EVCP's files are unlikely to be inconsistent in light of the context in which they were made. See United States v. Barrow, 400 F.3d 109, 123 (2d Cir. 2005) (citing United States v. Strother, 49 F.3d 869, 875 (2d Cir. 1995) for the proposition that an omission in a prior

ein Accuser Urged FBI to Investigate Trump Decades Ago The Guardian (07/21, Staff Writer) reported that S an artist who accused Jeffrey Epstein and Ghislaine Maxwell of sexual assault in 1996, claims she urged the FBI to investigate Donald Trump and others close to Epstein at the time. According to the a

artist who accused Jeffrey Epstein and Ghislaine Maxwell of sexual assault in 1996, claims she urged the F

tory. Additional reporting on the story was provided by Washington Past (07/21, Wells), Newsweek (07/21, Gooding, Castro), Associated Press (07/21, Barrow), Forbes (07/21, Roush), Fox News (07/21, Williams), Time (07/21, Popli), New York Post (07/21, Nava), Wall Street Journal (07/21, Pisani), The Guar