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

is a prevailing party, or alternatively, that a district court has discretion to award costs to the defendant.”); see also Carter v. Inc. Vill. of Ocean Beach, 759 F.3d 159, 165 (2d Cir. 2014) (disclaiming prior Second Circuit dicta which stated that “generally the defendant is not considered the prevailin

1(a)(2). In connection with her motion, Plaintiff filed a proposed order of dismissal imposing certain conditions (the "Proposed Order"). Defendant Ghislaine Maxwell opposed the motion. For the following reasons, subject to Plaintiff's consent, dismissal is granted pursuant to the terms of the Proposed Order modi

suant to the terms of the Proposed Order modified as described below. I. BACKGROUND On November 12, 2019, Plaintiff filed a Complaint against Ms. Maxwell and Defendants Darren K. Indyke and Richard D. Kahn in their official capacities as appointed executors of the Estate of Jeffrey E. Epstein (the "E

ain conditions (the "Proposed Order"). Defendant Ghislaine Maxwell opposed the motion. For the following rea

ber 12, 2019, Plaintiff filed a Complaint against Ms. Maxwell and Defendants Darren K. Indyke and Richard D. K

r a court order provides otherwise, costs -- other than attorney's fees -- should be allowed to the prevailing party."); see Carter v. Inc. Vii/. of Ocean Beach, 759 F.3d 159, 165 (2d Cir. 2014) ("A voluntary dismissal of an action with prejudice works [a material alteration of the legal relationship of the

411)(2). In connection with her motion, Plaintiff filed' proposed order of dismissal imposing certain conditions (the "Proposed Order"). Defendant Ghislaine Maxwell opposed the motion. For the following reasons, subject to Plaintiff's consent, dismissal is granted pursuant to the terms of the Proposed Order modi

nt to the terms of the Proposed Order modified as described below. I. BACKGROUND On November 12, 2019, Plaintiff filed I Complaint against Ms. Maxwell and Defendants Darren K. Indyke and Richard D. Kahn in their official capacities as appointed executors of the Estate of Jeffrey E. Epstein (the "E

ain conditions (the "Proposed Order"). Defendant Ghislaine Maxwell opposed the motion. For the following rea

12, 2019, Plaintiff filed I Complaint against Ms. Maxwell and Defendants Darren K. Indyke and Richard D. K

or' court order provides otherwise, costs -- other than attorney's fees -- should be allowed to the prevailing party."); see Carter v. Inc. VIII of Ocean Beach, 759 F.3d 159, 165 (2d Cir. 2014) (", voluntary dismissal of an action with prejudice works [I material alteration of the legal relationship of the