Epstein Secrets

5-cv-07433-LAP Document 1 Filed 09/21/15 Page 2 of 12 Plaintiff, formerly known as (a'), for her Complaint against Defendant, GHISLAINE MAXWELL ("Maxwell"), avers upon personal knowledge as to her own acts and status and otherwise upon information and belief: NATURE OF THE ACTION 1. This suit aris

d repeated sexual abuse after being recruited by Ghislaine Maxwell and Jeffrey Epstein when was under the a

727 --- PAGE BREAK --- Case 1:15-cv-07433-LAP Document 1 Filed 09/21/15 Page 3 of 12 PARTIES 6. Plaintiff is an individual who is a citizen of the State of Colorado. 7. Defendant Maxwell, who is domiciled in the Southern District of New York, is not a citizen of the state of Colorado. FACTUAL ALLEGATIONS 8.

egations have been "shown to be untrue." (c) That "claims are obvious lies." 31. Maxwell's January 3, 2015, statement incorporated by reference "Ghislaine Maxwell's original response to the lies and defamatory claims remains the same," an earlier statement that had falsely described factual assertions as "ent

Case 1:15-cv-07433-RWS Document 525 Filed 01/05/17 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-RWS Declaration Of Jeffrey S. Pagliuca In Support Of Defendant's Motion In Limine to Exclude Expert Testimony

t for the Southern District of New York pro hac vice. I am a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell ("Maxwell") in this action. I respectfully submit this declaration in support of the Motion In Limine to Exclude Expert Testimony and Opinion of Pro

istrict of New York pro hac vice. I am a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell ("Maxwell") in this action. I respectfully submit this declaration in support of the Motion In Limine to Exclude Expert Testimony and Opinion of Professor Ter

pert Testimony and Opinion of Professor Terry Coonan, J.D. I. Jeffrey S. Pagliuca, declare as follows: 1. I am an attorney at law duly licensed in the State of Colorado and admitted to practice in the United States District Court for the Southern District of New York pro hac vice. I am a member of the law firm Hadd

Case 1:15-cv-07433 Document 1 Filed 09/21/15 Page 1 of 12 United States District Court Southern District of New York Plaintiff, CASE NO: v. GHISLAINE MAXWELL, Defendant. COMPLAINT Boles Schiller & Flexner LLP 575 Lexington Avenue New York. NY 10022 EFTA00676990 Case 1:15-cv-07433 Document 1

1:15-cv-07433 Document 1 Filed 09/21/15 Page 2 of 12 Plaintiff, , formerly known as In), for her Complaint against Defendant, GHISLAINE MAXWELL ("Maxwell"), avers upon personal knowledge as to her own acts and status and otherwise upon information and belief: NATURE OF THE ACTION 1. This suit aris

a citizen of the state of Colorado. FACTUAL ALLEGATIONS 8. became a victim of sex trafficking and repeated sexual abuse after being recruited by Ghislaine Maxwell and Jeffrey Epstein whe of eighteen. 9. vas under the age Between 1999 and 2002, with the assistance and participation of Maxwell, Epstein sexua

his Court. 2 EFTA00676991 Case 1:15-cv-07433 Document 1 Filed 09/21/15 Page 3 of 12 PARTIES. 6. Plaintiff is an individual who is a citizen of the State of Colorado. 7. Defendant Maxwell, who is domiciled in the Southern District of New York, is not a citizen of the state of Colorado. FACTUAL ALLEGATIONS 8.