Epstein Secrets

. EPSTEIN, GHISLAINE MAXWELL, an individual, Defendants. 20-cv-00484-JGK ------------------------------------------------------X GHISLAINE MAXWELL’S MEMORANDUM OF LAWIN SUPPORT OF HER APPLICATION FOR COSTS SOUGHT AGAINST PLAINTIFF Laura A. Menninger HADDON, MORGAN, AND F

case with prejudice, based on her motion for voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(2). As the prevailing party in this matter, Ms. Maxwell hereby requests, pursuant to Fed. R. Civ. P. 54(d)(1), an order awarding her taxable costs against plaintiff Jane Doe. Rule 54(d)(1) provides that

amount detailed in the attached. WHEREFORE, Ms. Ghislaine Maxwell requests an award of costs pursuant to Fe

(a)(2). As the prevailing party in this matter, Ms. Maxwell hereby requests, pursuant to Fed. R. Civ. P. 54(d

for Costs Sought Against Plaintiff with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following: Kevin Boyle Robert Glassman Panish, Shea & Boyle 11111 Santa Monica Blvd., Ste 700 Los Angeles, CA 90025 [email protected] [email protected] Bennet J. Mo

executors of the ESTATE OF JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, an individual, Defendants. 20-cv-004

0 and 1923, granting fees and costs sought by Ms. Maxwell and granting such other relief that this Court d

1, I electronically filed the foregoing Defendant Ghislaine Maxwell’s Notice of Application for Costs Sought

1920 and 1923, granting fees and costs sought by Ms. Maxwell and granting such other relief that this Court d

notification of such filing to the following: Kevin Boyle Robert Glassman Panish, Shea & Boyle 11111 San

gation for corroboration and what the appropriate timing and format of that would be, and to start to talk about specific conduct by Epstein and/or Maxwell to whatever extent EWEN is comfortable with that at this stage. And we'll also likely refresh on some other topics as well, but just to flag some of

riginal Messa e From: Sent: Friday, January 24, 2020 03:45 To: Robert Glassman Cc: Nathan Werksman < Subject: RE: SDNY investigation Robert, ; Kevin Boyle < aNIMIN>; Apologies for the belated reply, it's been a crazy week for us, but we'd be happy to talk. We should be generally available tomorrow (F

26 27 28 JANE DOE, Plaintiff, v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, an individual, Defendants. Case No. COMPLAINT FOR DAMAGES DEMAND FOR JURY TRIAL PlaintiffJane Doe ("Doe" or "Plaintiff") alleges as follows: I

d convicted sex offender Jeffrey Epstein ("Epstein"). It all started in 1994 when 13-year-old Jane Doe met Epstein and Defendant Ghislaine Maxwell ("Maxwell") at a summer camp in Michigan. Jane Doe was their first known victim and was subsequently abused by Epstein and Maxwell for years as a young girl,

en 13-year-old Jane Doe met Epstein and Defendant Ghislaine Maxwell ("Maxwell") at a summer camp in Michigan

rate allowed by law; and 62. Grant such further relief as this Court may deem just and proper. Respectfully submitted, Dated: January 16, 2020 Kevin Boyle (admission pending) Robert Glassman (admission pending) Nathan Werksman (admission pending) PANISH SHEA & BOYLE LLP 11111 Santa Monica Blvd., Sui