Epstein Secrets

ecution. The Court should reject the "non-protective" order proposed by Plaintiff and enter the reasonable, and enforceable, order submitted by Ms. Maxwell. The True Facts Plaintiff, on February 4, 5 and 12, 2016, unilaterally and without conferral noticed a number of depositions in Florida and New Yo

aura A. Menninger Laura A. Menninger (LM-1374) HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 Phone: Fax: Attorney for Ghislaine Maxwell CERTIFICATE OF SERVICE I certify that on March 9, 2016, I electronically served this DEFENDANT'S REPLY IN FURTHER SUPPORT OF MOTION FOR PROTECTIVE

SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL. Defendant. X 15-cv-07433-RWS DEFENDA

reasonable, and enforceable, order submitted by Ms. Maxwell. The True Facts Plaintiff, on February 4, 5 and

mant's "deposition transcript, interrogatory answers and affidavit in any criminal proceeding brought against him by the United States Attorney for the District of Massachusetts," with certain exceptions); Securities and Exchange Commission v. Gilbert, 79 F.R.D. 683, 687 (S.D.N.Y. 1978) (ordering the SEC "not to furnish the

over up what needs to be brought to light. Jeffrey is no longer here, and the women that helped him are, Ghislaine Maxwell. My experience is with Ghislaine Maxwell and Sarah Kellen, and they definitely need to be held accountable for helping him, helping themselves, helping one another carry on this huge, almo

aking this morning is Sarah Ransome. MS. RANSOME: Thank you, your Honor. My name is Sarah Ransome, R-a-n-s-o-m-e. I'm a victim of Jeffrey Epstein and Ghislaine Maxwell's international sex trafficking ring. I would like to thank the Court for the dignity and the respect you are showing me here today, as well as the oth

by Ghislaine Maxwell. Upon my first meeting of her, I wouldn't know I had been recruited until many years later, when I would read it in a headline. Ghislaine and Jeffrey took me in. They sent me to school. They gave me a job. They flew me around the world, introduced me to a world I SOUTHERN DISTRICT REPOR

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 flun

ake a judgment with his own independent investigation. THE COURT: OK. MR. WEINBERG: If I could just add one precedent, your Honor. The Chief judge in the District of Massachusetts or the Chief Judge at the time, Judge Wolf, in a case called U.S, v. Fleming, when the conditions at Walpole, which is a state prison where federal p

cCAWLEY: The next client of ours that will be speaking this morning is MS. Thank you, your Honor. My name is I'm a victim of Jeffrey Epstein and Ghislaine Maxwell's international sex trafficking ring. I would like to thank the Court for the dignity and the respect you are showing me here today, as well as the o

y Ghislaine Maxwell. Upon my first meeting of her, I wouldn't know I had been recruited until many years later, when I would read it in a headline. Ghislaine and Jeffrey took me in. They sent me to school. They gave me a job. They flew me around the world, introduced me to a world I SOUTHERN DISTRICT RE

hat needs to be brought to light. Jeffrey is no longer here, and the women that helped him are, Ghislaine Maxwell. My experience is with Ghislaine Maxwell and , and they definitely need to be held accountable for helping him, helping themselves, helping one another carry on this huge, almost like a s

nity to make a judgment with his own independent investigation. THE COURT: OK. If I could just add one precedent, your Honor. The Chief judge in the District of Massachusetts or the Chief Judge at the time, Judge Wolf, in a case called U.S. v. Fleming, when the conditions at Walpole, which is a state prison where federa

LEY: The next client of ours that will be speaking this morning is MS. : Thank you, your Honor. My name is • I'm a victim of Jeffrey Epstein and Ghislaine Maxwell's international sex trafficking ring. I would like to thank the Court for the dignity and the respect you are showing me here today, as well as the o

y Ghislaine Maxwell. Upon my first meeting of her, I wouldn't know I had been recruited until many years later, when I would read it in a headline. Ghislaine and Jeffrey took me in. They sent me to school. They gave me a job. They flew me around the world, introduced me to a world I SOUTHERN DISTRICT RE

hat needs to be brought to light. Jeffrey is no longer here, and the women that helped him are, Ghislaine Maxwell. My experience is with Ghislaine Maxwell and , and they definitely need to be held accountable for helping him, helping themselves, helping one another carry on this huge, almost like a s

judgment with his own independent investigation. THE COURT: OK. MR. WEINBERG: If I could just add one precedent, your Honor. The Chief judge in the District of Massachusetts or the Chief Judge at the time, Judge Wolf, in a case called U.S. v. Fleming, when the conditions at Walpole, which is a state prison where federa

MS. McCAWLEY: The next client of ours that will be speaking this morning is Thank you, your Honor. My name is I'm a victim of Jeffrey Epstein and Ghislaine Maxwell's international sex trafficking ring. I would like to thank the Court for the dignity and the respect you are showing me here today, as well as the o

y Ghislaine Maxwell. Upon my first meeting of her, I wouldn't know I had been recruited until many years later, when I would read it in a headline. Ghislaine and Jeffrey took me in. They sent me to school. They gave me a job. They flew me around the world, introduced me to a world I SOUTHERN DISTRICT RE

hat needs to be brought to light. Jeffrey is no longer here, and the women that helped him are, Ghislaine Maxwell. My experience is with Ghislaine Maxwell and , and they definitely need to be held accountable for helping him, helping themselves, helping one another carry on this huge, almost like a s

judgment with his own independent investigation. THE COURT: OK. MR. WEINBERG: If I could just add one precedent, your Honor. The Chief judge in the District of Massachusetts or the Chief Judge at the time, Judge Wolf, in a case called U.S. v. Fleming, when the conditions at Walpole, which is a state prison where federa

cCAWLEY: The next client of ours that will be speaking this morning is MS. Thank you, your Honor. My name is I'm a victim of Jeffrey Epstein and Ghislaine Maxwell's international sex trafficking ring. I would like to thank the Court for the dignity and the respect you are showing me here today, as well as the o

y Ghislaine Maxwell. Upon my first meeting of her, I wouldn't know I had been recruited until many years later, when I would read it in a headline. Ghislaine and Jeffrey took me in. They sent me to school. They gave me a job. They flew me around the world, introduced me to a world I SOUTHERN DISTRICT RE

hat needs to be brought to light. Jeffrey is no longer here, and the women that helped him are, Ghislaine Maxwell. My experience is with Ghislaine Maxwell and , and they definitely need to be held accountable for helping him, helping themselves, helping one another carry on this huge, almost like a s

judgment with his own independent investigation. THE COURT: OK. MR. WEINBERG: If I could just add one precedent, your Honor. The Chief judge in the District of Massachusetts or the Chief Judge at the time, Judge Wolf, in a case called U.S. v. Fleming, when the conditions at Walpole, which is a state prison where federa

LEY: The next client of ours that will be speaking this morning is MS. : Thank you, your Honor. My name is • I'm a victim of Jeffrey Epstein and Ghislaine Maxwell's international sex trafficking ring. I would like to thank the Court for the dignity and the respect you are showing me here today, as well as the o

y Ghislaine Maxwell. Upon my first meeting of her, I wouldn't know I had been recruited until many years later, when I would read it in a headline. Ghislaine and Jeffrey took me in. They sent me to school. They gave me a job. They flew me around the world, introduced me to a world I SOUTHERN DISTRICT RE

hat needs to be brought to light. Jeffrey is no longer here, and the women that helped him are, Ghislaine Maxwell. My experience is with Ghislaine Maxwell and , and they definitely need to be held accountable for helping him, helping themselves, helping one another carry on this huge, almost like a s

judgment with his own independent investigation. THE COURT: OK. MR. WEINBERG: If I could just add one precedent, your Honor. The Chief judge in the District of Massachusetts or the Chief Judge at the time, Judge Wolf, in a case called U.S. v. Fleming, when the conditions at Walpole, which is a state prison where federa

judgment with his own independent investigation. THE COURT: OK. MR. WEINBERG: If I could just add one precedent, your Honor. The Chief judge in the District of Massachusetts or the Chief Judge at the time, Judge Wolf, in a case called U.S. v. Fleming, when the conditions at Walpole, which is a state prison where federa

er that have, which manifests into violent vomiting attacks, largely triggered by stress. It's called Cyclic Vomiting Syndrome. I was recruited by Ghislaine Maxwell. Upon my first meeting of her, I wouldn't know I had been recruited until many years later, when I would read it in a headline. Ghislaine and Jeff

y Ghislaine Maxwell. Upon my first meeting of her, I wouldn't know I had been recruited until many years later, when I would read it in a headline. Ghislaine and Jeffrey took me in. They sent me to school. They gave me a job. They flew me around the world, introduced me to a world I SOUTHERN DISTRICT RE

hat needs to be brought to light. Jeffrey is no longer here, and the women that helped him are, Ghislaine Maxwell. My experience is with Ghislaine Maxwell and and they definitely need to be held accountable for helping him, helping themselves, helping one another carry on this huge, almost like a sys