9
Shared Docs
9
Same-Page
37 / 9
Mentions
LAINE MAXWELL JEFFREY EPSTEIN, PRINCE ANDREW, 3/22/20 EFTA00084370 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 6 of 161 Socialite Ghislaine Maxwell 'groped a 16-year-old girl during a naked massage,' victims' lawyer says O dailvmaitco.uk/news/article-8163681/Socialite-Ghislaine-Maxwell-hroped-16-
ummer of 1994 at Michigan's Interlochen Arts Camp, where she was In voice training, according to newly filed court papers suing Epstein's estate and Maxwell. The duo quickly took her under their wing, taking her to movies and on shopping trips in her home state of Florida and all the while grooming her
City — near his own townhouse, where he would allegedly rape her the next year. MAIM Feds finally start investigating Jeffrey Epstein's gal pal Ghislaine Maxwell "In 1997, while at Epstein's townhouse on 9 East 71st Street in the City of New York. Epstein asked 17-year-old Doe if she had a boyfriend
By Jams mu and Pelt Nbadta My 10.2020.2:06AM • mm rrad 11 ir • Obtains Maxwal behind bars as now details emerge Jeffrey Epstein's ex-girlfriend Ghatoine Maxwell is accused of facilitating Epstein's sex crimes by ',sting him Mafia, groom and ultimately abuse three unnamed teens between 2994 and 1997. Ghislai
case. "Denial of a stay, particularly a stay of Ms. Maxwell's deposition, pending outcome of the criminal inv
Audrey Strauss called the sex abuse described in the Maxwell case "the prequel" to the charges they lodged la
pstein 'co-conspirators' on the same topic as Plaintiff alleges in this case," Maxwell's attorney wrote in a May13 letter to Manhattan federal Judge Debra Freeman seeking to stay discovery in the case. "Denial of a stay, particularly a stay of Ms. Maxwell's deposition, pending outcome of the criminal investiga
MAXWELL JEFFREY EPSTEIN, PRINCE ANDREW, 3/22/20 EFTA00075107 Casgastetal14331atitilmetbdOnttit7187.82412CF 057g9/28gEFEeigef 6208161 Socialite Ghislaine Maxwell 'groped a 16-year-old girl during a naked massage,' victims' lawyer says El dailvmail.co.ukThews/article-8163681/Socialite-Ghislaine-Maxwell-qroped-1
.com Re: Reconsideration of the Court's July 23 Ruling Giuffie v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its Protective Order and punish its violation. Ms. Maxwell's two deposition transcripts were designated
rated for Jeffrey Epstein's personal sexual satisfaction. So to the degree that um there was a main facilitator that started the whole thing, it was Ghislaine. 3 A purported transcript of the press conference is contained on the intemet at https://www.rev.comiblog,/transcripts/announcement-transcript-of-c
v. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its
ining the Maxwell materials from Boies Schiller, the Maxwell Protective Order explicitly provides that (1) di
pstein 'co-conspirators' on the same topic as Plaintiff alleges in this case," Maxwell's attorney wrote in a May13 letter to Manhattan federal Judge Debra Freeman seeking to stay discovery in the case. "Denial of a stay, particularly a stay of Ms. Maxwell's deposition, pending outcome of the criminal investiga
t aL Dear Judge Freeman: On behalf of defendant Ghislaine Maxwell, I write to Move to Stay proceedings in
Page: EFTA00026735 →of the courts, the public, the other parties and Ms. Maxwell all will best be served by a stay of this civil
Page: EFTA00026735 →7-1312 Re: Letter Motion to Stay Proceedings 20-cv-484 (JGK-DCF), Jane Doe v. Darren K. Indyke, et aL Dear Judge Freeman: On behalf of defendant Ghislaine Maxwell, I write to Move to Stay proceedings in this matter until the conclusion of her pending criminal case. "[T]he power to stay proceedings is incident
Page: EFTA00026735 →letier S.A. v. LY USA, Inc., 676 F.3d 83, 96 (2d Cir. 2012) (citations omitted). The interests of the courts, the public, the other parties and Ms. Maxwell all will best be served by a stay of this civil case. A stay will allow Ms. Maxwell to vigorously contest her criminal charges, and there is little
Page: EFTA00026735 →n and Foreman, r.c Laura A. Menninger 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FR 303.832.2628 August 19, 2020 VIA ECF Hon. Debra Freeman United States Magistrate Judge Daniel Patrick Moynihan United States Courthouse 500 Pearl St. New York, NY 10007-1312 Re: Letter Motion to Sta
Page: EFTA00026735 →n Support of Letter Motion to Stay Proceedings 20-cv-484 (JGK-DCF), Jane Doe v. Darren K. Indyke, et at Dear Judge Freeman: On behalf of defendant Ghislaine Maxwell, I write in further support of a Motion to Stay Proceedings in this matter until the conclusion of the criminal trial in United States v. Maxwell,
e Maxwell, I write in further support of a Motion to Stay Proceedings in this matter until the conclusion of the criminal trial in United States v. Maxwell, 20 Cr. 330 (AJN) ("Criminal Case"). Plaintiff apparently concedes, by failing to respond, that (a) she is one of the three accusers mentioned in t
t at Dear Judge Freeman: On behalf of defendant Ghislaine Maxwell, I write in further support of a Motion
nal Case to proceed first, and (e) absent a stay, Ms. Maxwell will be forced to choose between her constitutio
O East 10th Avenue Denver. Colorado 80203 rti 303.831.7364 rx 303.832.2628 www.hmflaw.com Imenningerehmflaw.com September 4, 2020 VIA ECF Hon. Debra Freeman United States Magistrate Judge Daniel Patrick Moynihan United States Courthouse 500 Pearl St. New York, NY 10007-1312 Re: Reply in Support of
Denver. Colorado 80203 PH 303.831.7364 rx 303.832.2628 www.hmflaw.corn Imenningerathmflaw.com v. Darren K Indyke, et aL On behalf of defendant Ghislaine Maxwell, I write under Judge Schofield's Individual Rules and Procedures for Civil Cases III(A)(1) and this Court's Practices II(A) to request a pre-motion
articipate in the Program and accept payment will be required to release all former employees or potential indemnitees of the Estate, including Ms. Maxwell, from any and all claims or causes of action that concern acts of sexual abuse by Mr. Epstein. We understand that, if the Program is approved, it ma
v. Darren K Indyke, et aL On behalf of defendant Ghislaine Maxwell, I write under Judge Schofield's Individ
2 of 3 Hon. Debra Freeman May 13, 2020 Page 2 Ms. Maxwell has asserted her plan to undertake a vast, broa
Case 1:19-cv-10475-LGS-DCF Document 68 Filed 05/13/20 Page 1 of 3 H A D D O N MORGAN FOREMAN May 13, 2020 VIA ECF Hon. Debra Freeman United States Magistrate Judge Daniel Patrick Moynihan United States Courthouse 500 Pearl St. New York, NY 10007-1312 Re: 19-cv- 10475 (LGS-DC
questioned as part of a lawsuit filed by Jane Doe, who alleges she was 14 when Epstein and his former girlfriend, British socialite EFTA00163121 Ghislaine Maxwell, began to groom and sexually abuse her in 1994. (Doe is suing Indyke and Kahn in their capacity as co-executors, and Maxwell individually.) Maxwel
FTA00163121 Ghislaine Maxwell, began to groom and sexually abuse her in 1994. (Doe is suing Indyke and Kahn in their capacity as co-executors, and Maxwell individually.) Maxwell, who is in a federal prison in Brooklyn awaiting trial for her alleged role in Epstein's teen sex ring, could also sit for
mer girlfriend, British socialite EFTA00163121 Ghislaine Maxwell, began to groom and sexually abuse her in
now to what extent he knew about Mr. Epstein and Ms. Maxwell's criminal enterprise. We would like to know if
even acted on Jeffrey Epstein's behalf to communicate with Plaintiff on several occasions," the lawyer Robert Glassman wrote to U.S. District Judge Debra Freeman, responding to the estate's push to delay the under-oath grilling. Doe also plans to depose Kahn. In an email thread attached to his letter, Glass
questioned as part of a lawsuit filed by Jane Doe, who alleges she was 14 when Epstein and his former girlfriend, British socialite EFTA01654939 Ghislaine Maxwell, began to groom and sexually abuse her in 1994. (Doe is suing Indyke and Kahn in their capacity as co-executors, and Maxwell individually.) Maxwel
FTA01654939 Ghislaine Maxwell, began to groom and sexually abuse her in 1994. (Doe is suing Indyke and Kahn in their capacity as co-executors, and Maxwell individually.) Maxwell, who is in a federal prison in Brooklyn awaiting trial for her alleged role in Epstein's teen sex ring, could also sit for
mer girlfriend, British socialite EFTA01654939 Ghislaine Maxwell, began to groom and sexually abuse her in
now to what extent he knew about Mr. Epstein and Ms. Maxwell's criminal enterprise. We would like to know if
even acted on Jeffrey Epstein's behalf to communicate with Plaintiff on several occasions," the lawyer Robert Glassman wrote to U.S. District Judge Debra Freeman, responding to the estate's push to delay the under-oath grilling. Doe also plans to depose Kahn. In an email thread attached to his letter, Glass
imited purpose of seeking a stay of the action, and (2) stay this matter in its entirety pending the resolution of the criminal prosecution against Ghislaine Maxwell in the matter of United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN). As discussed below, the Government submits that a complete stay of this civil
Page: EFTA00024724 →nt submits that a complete stay of this civil action will serve the public interest of preserving the integrity of the criminal prosecution against Maxwell and will conserve private, public, and judicial resources; and that those interests will outweigh any delay or disruption caused to the resolution o
Page: EFTA00024724 →F Document 80 Filed 09/09/20 Page 1 of 4 U.S. Department of Justice United States Attorney Southern District of New York BY EMAIL' The Honorable Debra Freeman United States District Court Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007 The Silvio J. Mol
Page: EFTA00024724 →Judge Nathan held that Maxwell is not entitled to know who the Government's trial witnesses are at this stage of the criminal case. United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN), Dkt. 49. Consistent with that ruling, the Government is not including detailed information in this letter about who thos
Page: EFTA00024726 →: ' (NY) (FBI)" Date: May 26, 2020 08:17 Subject: U ate To: " (CID) (FBI)" Cc: Hi - can we get an update on where we/SDNY stand re her...? Ghislaine Maxwell Wins Questioning Delay In Epstein Lawsuit. Fox News (5/23, Chakraborty, 27.59M) reports, "Ghislaine Maxwell, the alleged madam of disgraced
pdate on where we/SDNY stand re her...? Ghislaine Maxwell Wins Questioning Delay In Epstein Lawsuit. Fox News (5/23, Chakraborty, 27.59M) reports, "Ghislaine Maxwell, the alleged madam of disgraced financier Jeffrey Epstein, won a critical request on Friday to delay questioning in a civil suit filed against her o
during her ruling. `Not forever, but at least long enough to let us know whether the claims process is likely to go forward.' Fox News adds, "Though Maxwell faces multiple lawsuits against her for her role in Epstein's alleged nefarious activities, Friday's ruling specifically dealt with a lawsuit filed
riminal case against her in the future. `I'm permitting her not to respond to (written questions) and not to have her deposition,' Magistrate Judge Debra Freeman said during her ruling. `Not forever, but at least long enough to let us know whether the claims process is likely to go forward.' Fox News adds, "T
Entities connected to both Ghislaine Maxwell and Debra Freeman

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Bill Clinton
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATION
Marc Rich
PERSON
Donald Trump
PERSONJeffrey Pagliuca
PERSONLeon Black
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATIONLaura Menninger
PERSONDarren Indyke
PERSON
Virginia Giuffre
PERSON
New York
LOCATIONMaria Farmer
PERSON
Les Wexner
PERSON
Alison J. Nathan
PERSONJane Doe
PERSON
Denver
LOCATION