Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff. v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S OPPOSITION TO MESSRS. CASSELL AND EDWARDS' RENEWED MOTIONS TO APPEAR PRO HAC VICE Defendant G

E MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S OPPOSITION TO MESSRS. CASSELL AND EDWARDS' RENEWED MOTIONS TO APPEAR PRO HAC VICE Defendant Ghislaine Maxwell, by and through her attorneys, hereby submits the following opposition to Messrs. Cassell and Edwards' Renewed Motions to Appear Pro Hac Vice in th

them to you now. You should have them shortly." Id. At 5:49 p.m., Plaintiff's counsel sent a document with an unsent fax cover sheet, to which Ms. Maxwell's counsel requested to know "when these were filed with the Court." Id. Ms. McCawley, at 6:02 p.m. stated that she "gave it to staff for faxing and

ocument with an unsent fax cover sheet, to which Ms. Maxwell's counsel requested to know "when these were fil

ects that the matter is set for the trial calendar between August 29, 2016 and November 4, 2016. See Epstein v. Edwards, Case No. 2009-CA-040800, In the Circuit Court of EFTA00605450 the Fifteenth Judicial Circuit, Palm Beach County, Florida https://showcase.mypalmbeachclerk.com/ showcaseweb/#CaseSearch (last a

HERN DISTRICT OF NEW YORK X L. Plaintiff. v. GHISLAINE MAXWELL. Defendant. X 15-cv-07433-RWS Objecti

d by Bradley Edwards (Doc#86). In the alternative Ms. Maxwell requests that the Court modify the Protective Or

EMAN, P.C. East 10th Avenue Denver, CO 80203 EFTA00595640 Case 1:15-cv-07433-RWS Document 88 Filed 04/08/16 Page 2 of 7 INTRODUCTION Defendant Ghislaine Maxwell, through her attorneys, objects to the Motion for Admission Pro Hac Vice filed by Bradley Edwards (Doc#86). In the alternative Ms. Maxwell requests

Ghislaine Maxwell, through her attorneys, objects to the Motion for Admission Pro Hac Vice filed by Bradley Edwards (Doc#86). In the alternative Ms. Maxwell requests that the Court modify the Protective Order, (Doc. # 62) to restrict Mr. Edwards's access to information designated "confidential" for the

f and Counterclaim Defendant in an action captioned Edwards and Edwards, Plaintiffs and Counterclaim Defendants v. Dershowitz, 15-000072 pending in the Circuit Court in Broward County, Florida. The subject of that litigation includes allegations made by Mr. Edwards during his representation of the Plaintiff in th

Case 1:15-cv-07433-RWS Document 88 Filed 04/08/16 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X L. Plaintiff, v. GHISLAINE MAXWELL Defendant. X 15-cv-07433-RWS Objection to Motion to Appear Pro Hac Vice of Bradley James aim, ards or, Alternatively, to Modify the Prot

15-cv-07433-RWS Document 88 Filed 04/08/16 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X L. Plaintiff, v. GHISLAINE MAXWELL Defendant. X 15-cv-07433-RWS Objection to Motion to Appear Pro Hac Vice of Bradley James aim, ards or, Alternatively, to Modify the Protection O

REMAN, P.C. East 10th Avenue Denver, CO 80203 EFTA00595633 Case 1:15-cv-07433-RWS Document 88 Filed 04/08/16 Page 2 of 7 INTRODUCTION Defendant Ghislaine Maxwell, through her attorneys, objects to the Motion for Admission Pro Hac Vice filed by Bradley Edwards (Doc#86). In the alternative Ms. Maxwell requests

d by Bradley Edwards (Doc#86). In the alternative Ms. Maxwell requests that the Court modify the Protective Or

f and Counterclaim Defendant in an action captioned Edwards and Edwards, Plaintiffs and Counterclaim Defendants v. Dershowitz, 15-000072 pending in the Circuit Court in Broward County, Florida. The subject of that litigation includes allegations made by Mr. Edwards during his representation of the Plaintiff in th

he background as he navigated New York high society. When he first attracted notice in the early 1990s, it was on account of the woman he was dating: Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell. In a lengthy article, headlined "The Mystery of Ghislaine Maxwell’s Secret Love,” the Brit

s beau was a CIA spook, a math teacher, a concert pianist or a corporate headhunter, "But what is the truth about him?” the newspaper wondered. "Like Maxwell, Epstein is both flamboyant and intensely private.” The media frenzy did not begin in full until a decade later. In September 2002, Epstein was flung

0s, it was on account of the woman he was dating: Ghislaine Maxwell, daughter of the late British media tycoo

County, Florida, in her official capacity (“Court Clerk”), alleges as follows: JURISDICTION L This is an action within the exclusive,jurisdiction of the Circuit Court pursuant to Fla. Stat. Sections 26.012(2)(a) and 86.011 et seq. PARTIES 2. The Palm Beach Post is a daily community newspaper published by Plaintiff

he background as he navigated New York high society. When he first attracted notice in the early 1990s, it was on account of the woman he was dating: Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell. In a lengthy article, headlined "The Mystery of Ghislaine Maxwell’s Secret Love,” the Brit

s beau was a CIA spook, a math teacher, a concert pianist or a corporate headhunter. "But what is the truth about him?” the newspaper wondered. "Like Maxwell, Epstein is both flamboyant and intensely private.” The media.frenzy did not begin iri full until a decade later. In September 2002, Epstein was flun

0s, it was on account of the woman he was dating: Ghislaine Maxwell, daughter of the late British media tycoo

County, Florida, in her official capacity (“Court Clerk”), alleges as follows: JURISDICTION 1. This is an action within the exclusive jurisdiction of the Circuit Court pursuant to Fla. Stat. Sections 26.012(2)(a) and 86.011 et seq. PARTIES 2. The Palm Beach Post is a daily community newspaper published by Plaintiff

background as he navigated New York high society. When he first attracted notice in the early 1990s, it was on account of the woman he was dating: Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell. In a lengthy article, headlined "The Mystery of Ghislaine Maxwell's Secret Love," the Bri

beau was a CIA spook, a math teacher, a concert pianist or a corporate headhunter. "But what is the truth about him?" the newspaper wondered. "Like Maxwell, Epstein is both flamboyant and intensely private." The media frenzy did not begin in full until a decade later. In September 2002, Epstein was fl

s, it was on account of the woman he was dating: Ghislaine Maxwell, daughter of the late British media tycoo

unty, Florida, in his official capacity (“Court Clerk”), alleges as follows: JURISDICTION 1. This is an action within the exclusive jurisdiction of the Circuit Court pursuant to Fla. Stat. Sections 26.012(2)(a) and 86.011 et seq. PARTIES 2. The Palm Beach Post is a daily community newspaper published by Plaintif

r women, among their other duties, worked to ensure that an appointment book for twice- or thrice-daily "massages" was stocked with fresh recruits. Ghislaine Maxwell, daughter of the late Czechoslovakian-born press baron Robert Maxwell. who was for many years Epstein's live-in partner, also recruited young girls.

odeling agency. According to a complaint filed in the U.S. District Court for the Southern Di trict of Florida, an alleged victim said that Epstein, Maxwell. Brunel, Rodriguez, and "deliberately engaged in a pattern of racketeering that involved luring minor children through MC2, mostly girls under the

cording to a complaint filed in the U.S. District Court for the Southern District of Florida, an alleged victim said that Epstein • and girlfriend Ghislaine] Maxwell, Brunel. [house manager Alfredo] Rodriguez. and 'deliberately engaged in a pattern of racketeering that involved luring minor children thro

authorizes service on both out-of-state Defendants (Tyler McDonald. and Tyler McDonald d/b/a/ Yi.Org). EFTA00599859 3. Jurisdiction is proper in the Circuit Court as this action seeks relief in excess of fifteen- thousand dollars ($15,000). FACTUAL ALLEGATIONS AS TO DEFENDANT JEFFREY EPSTEIN 4. Plaintiff Jea

our women, among their other duties, worked to ensure that an appointment book for twice- or thrice-daily “massages” was stocked with fresh recruits. Ghislaine Maxwell, daughter of the late Czechoslovakian-born press baron Robert Maxwell, who was for many years Epstein’s live-in partner, also recruited young girls.

modeling agency. According to a complaint filed in the U.S. District Court for the Southern District of Florida, an alleged victim said that Epstein, Maxwell, Brunel, Rodriguez, and Marcinkova “deliberately engaged in a pattern of racketeering that involved luring minor children through MC2, mostly girls u

to a complaint filed in the U.S. District Court for the Southern District of Florida, an alleged victim said that Epstein, [assistant and girlfriend Ghislaine] Maxwell, Brunel, [house manager Alfredo] Rodriguez, and Marcinkova ‘deliberately engaged in a pattern of racketeering that involved luring minor chi

es service on both out-of-state Defendants (Tyler McDonald, and Tyler McDonald d/b/a/ Yi.Org). HOUSE_OVERSIGHT_011912 3. Jurisdiction is proper in the Circuit Court as this action seeks relief in excess of fifteen- thousand dollars ($15,000). FACTUAL ALLEGATIONS AS TO DEFENDANT JEFFREY EPSTEIN 4. Plaintiff Jean-

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

ds' Motion to Strike these statements without even giving Epstein the opportunity to respond and Edwards withdrew his Motion for Sanctions filed in the Circuit Court. 14 EFTA00808717 C. Bankruptcy Court D.E. 6351 Date Document 04/09/18 Epstein's Response in Opposition to Farmer Jaffe's Motion for Issua

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l or penal cause growing out of the having or possession of said property. WITNESS my hand and seal this 18th day of October, A.D., 2005. JUDGE of the Circuit Court of the Fifteen Judicial Circuit in and for Palm Beach County, Florida. EFTA00232949 AFFIDAVIT AND APPLICATION FOR SEARCH WARRANT IN THE CIRCUI