Epstein Secrets

No. 2 v. Epstein Page 17 Request No. 17. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Response: Defendant is asserting

munications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes,

ng to communications between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters,

ch other relief as this Court deems just and proper. Dated: March 2, 2009 Respectfully submitted, By: s/ Adam D. Horowitz Stuart S. Mermelstein (FL Bar No. 947245) Adam D. Horowitz (It Bar No. 376980) MERMELSTEIN & HOROWITZ, P.A. Attorneys for Plaintiff 18205 Biscayne Blvd., Suite 2218 Miami, Florid

A. Yes, ma'am. Q. Did any of those appear to be Ms. Maxwell? A. Yes, ma'am. Q. You mentioned that who was

3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 322 A. Yes, ma'am. Q. Did any of those appear to be Ms. Maxwell? A. Yes, ma'am. Q. You mentioned that who was still working there when you A. Yes, ma'am. Q. — was a very religious woman -- A. Yes, ma'am. Q.

raised in the Motion and has been unable to do so. Dated: February 17, 2010 Respectfully submitted, By: /si Adam D. Horowitz Stuart S. I tein FL Bar No. 947245) Adam D. Horowitz Is Bar No. 376980) ar No. 67885) P.A. Attorneys for Plaintiffs 18205 Biscayne Blvd., Suite 2218 Mia Tel: Fax: 5 E

dent of Florida. 13440 This tax was received by GM FAXMakes fax server. For more information, visit

destroyed Plaintiff would be severely prejudiced. Dated: September 6, 2008 Respectfully submitted, By: s/Richard H. Willits Richard H. Willits (FL Bar No. 139888) RICHARD H. WILLITS, P.A. Attorne for Plaintiff 2290 10th Ave. North, Suite 404 Tel: Fax: 561-582-7600 EFTA00175479 Case 9:08-cv-8L.1-