Epstein Secrets

enies." "Ms. Roberts claims are obvious lies and should be treated as such and not publicized as news, as they are defamatory." 4 EFTA00792759 "Ghislaine Maxwell's original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavory nature, which have appeared

l was living in New York. Plaintiff is a United States Citizen. Plaintiff is seeking damages in excess of $75,000.00. Defendant's Statement: Ms. Maxwell agrees with the Plaintiff's statement, above. iv. A brief summary by each party of the claims and defenses that party has asserted which remain to

t the repetition of such old defamatory claims." GM 00068. Plaintiff's Complaint also seeks damages

York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant JOINT PRETRIAL STATEMENT Pu

in excess of $75,000.00. Defendant's Statement: Ms. Maxwell agrees with the Plaintiff's statement, above. iv

3100 New York, NY 10118 19. Ross Gow (video) 15 EFTA00792770 Acuity Representation 23 Berkeley Square London W1J 6HE 20. Brett Jaffe (live) Alston & Bird, LLP, NY 90 Park Avenue New York, NY 10016 21. Robert Hanson (live) 22. (live) do Philip Barden Devonshires Solicitors LLP 32 Finsbury Circus

ch he denies." "Ms. claims are obvious lies and should be treated as such and not publicized as news, as they are defamatory." 4 EFTA00617399 "Ghislaine Maxwell's original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavory nature, which have appeared

l was living in New York. Plaintiff is a United States Citizen. Plaintiff is seeking damages in excess of $75,000.00. Defendant's Statement: Ms. Maxwell agrees with the Plaintiff's statement, above. iv. A brief summary by each party of the claims and defenses that party has asserted which remain to

t the repetition of such old defamatory claims." GM 00068. Plaintiff's Complaint also seeks damages

York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant JOINT PRETRIAL STATEMENT Pu

in excess of $75,000.00. Defendant's Statement: Ms. Maxwell agrees with the Plaintiff's statement, above. iv

ve) 17. Anthony Figueroa (video) 18. Louis Freeh (live) SE 19. Ross Gow (video) 15 EFTA00617410 Acuit Re resentation 20. Brett Jaffe (live) Alston & Bird, LLP, NY 90 Park Avenue New York, NY 10016 21. Robert Hanson (live) 23. Brittany Henderson (video) 24. Peter Kent live 25. Guy Louthan (live)

"LR") • Richard Kahn (S) • Darren Indyke (S) • Erica Kellerhals (S) • Many Beller (S) BENEFICIARY ("B") OR LIMITED POA ("LPOA") • • hislaine Maxwell (B) • • Richard Kahn (B) • Darren Indyke (B) • Shuliak ) • • • • Darren Indyke PLLC Checking • Darren Indyke (UBO) • Darren Indyke (S)

s in connection with its sex trafficking probe into Epstein in November 2006.16 December 27, 2006 Epstein settles the Butterfly Trust, naming and "Gishlaine N. Maxwell" as beneficiaries. Richard Kahn and Darren Ind ke are named trustees. March 24, 2011 Darren Indyke and Richard Kahn add as a beneficiary. March

ALE BUTTERFLY TRUST BENEFICIARIES" Nvin I) O B CITIZENSHIP ADDRESS PROFESSION DATE DATE ADDED RENIOYED PI BLB CONNECT lov, TO EPs i r I\ Ghislaine Maxwell N/A IS N/A cio FIBRK Associates 575 Lexington Ave. 4th Floor New Yo NY N/A 12/27/2006 12/9/2014 Yes N/A N/A N/A 12/27/2006 12

given immunity in connection with Epstein's Non-Prosecution Agreement. 4) Through his attorney, Darren Ind l leffry Epstein appears to have paid for Ghislaine Maxwell's legal expenses in connection with a 2015 lawsuit filed against Maxwell by an Epstein accuser. See v e . Maxwell, 1:15-cv-07433 (S.D.N.Y. 2015). Ma

ATORS L tw FIRM BENEFICIARY PA1 MEN IS Tor.u. i r‘i i I. ‘c «fi \i BACKGROUND A I ston & Bird , $150,000 Co t 10-0 Darren K. Indyke PLLC Alston & Bird represented in the lawsuit Jane Doe 43 v. Epstein. 21) A I ston did not represent Epstein. The transaction dates coincide with the lawsuit. Coff

al N/A 1/12/2018 Lawrence P Visoski $150,000 Bank of America Southern Financial Promissory note 2/2/2018 Haddon, Morgan and Foreman, P.C. (Ghislaine Maxwell)" $21,379 Wells Fargo Bank Darren K. Indyke PLLC N/A 2/12/2018 Aviloop LLC'2 $40,000 TD Bank Jeffre E . stein N/A 2/12/2018 Hadd

12/2018 Lawrence P Visoski $150,000 Bank of America Southern Financial Promissory note 2/2/2018 Haddon, Morgan and Foreman, P.C. (Ghislaine Maxwell)" $21,379 Wells Fargo Bank Darren K. Indyke PLLC N/A 2/12/2018 Aviloop LLC'2 $40,000 TD Bank Jeffre E . stein N/A 2/12/2018 Haddon, Morga

2 Wells Fargo Bank Darren K. Indyke PLLC Reference Statement No " Through his attorney, Darren Indyke, Jeffrey Epstein appeals to have paid for Ghislaine Maxwell's legal expenses in connection with a 2015 lawsuit filed against Maxwell by an Epstein accuser. See Giuffre v. Maxwell, 1:15-cv.07433 (S.D.N.Y. 2015).

07433 (S.D.N.Y. 2015). Maxwell was represented by Haddon, Morgan and Foreman in the suit, Epstein was not. 12 Aviloop LLC is aviation company. 13 Alston & Bird represented C in the lawsuit referenced in Footnote 11. Alston & Bird did not represent Epstein. CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)

42952771 N/A 1/12/2018 $150,000 Bank of America Southern Financial 42952771 Promissory note 2/2/2018 I laddon, Morgan and Foreman, P.C. (Ghislaine Maxwell)" $21,379 Wells Fargo Bank Darren K. Indyke PLLC 42953707 N/A 2/12/2018 Aviloop LLC'2 $40,000 TD Bank Jeffrey Epstein 35269691 N

N/A 1/12/2018 $150,000 Bank of America Southern Financial 42952771 Promissory note 2/2/2018 I laddon, Morgan and Foreman, P.C. (Ghislaine Maxwell)" $21,379 Wells Fargo Bank Darren K. Indyke PLLC 42953707 N/A 2/12/2018 Aviloop LLC'2 $40,000 TD Bank Jeffrey Epstein 35269691 N/A 2/12/

argo Bank Darren K. Indyke PLLC 42953707 Reference Statement No " Through his attorney, Darren Indvke. Jeffrey Epstein appeals to have paid for Ghislaine Maxwell's legal expenses in connection with a 2015 lawsuit filed against Maxwell by an Epstein accuser. See v. Maxwell, 1:15-cv.07433 (S.D.N.Y. 2015). Maxwel

-cv.07433 (S.D.N.Y. 2015). Maxwell was represented by Haddon, Morgan and Foreman in the suit, Epstein was not. 12 Aviloop LLC i viation con an 13 Alston & Bird represente the lawsuit referenced in Footnote 11. Alston & Bird did not represent Epstein. CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) EFTA00

OF NEW YORK x 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Plaintiff, v. 17 Civ. 616 (JGK) JEFFERY EPSTEIN, GHISLAINE MAXWELL, and Defendants. Before: x New York, N.Y. August 7, 2018 2:30 p.m. HON. JOHN G. KOELTL District Judge APPEARANCES BOIES SCHILLER &

ERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00285631 I877DOEC APPEARANCES (Continued) HADDON MORGAN & FOREMAN P.C. Attorneys for Defendant Ghislaine Maxwell BY: LAURA MENNINGER 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ALSO PRESENT: ALEXANDER LORENZO SOUTHERN DIS

mises made by the defendants, plaintiff returned to New York City, in the Southern District of New York, and was promptly ordered by the defendant Maxwell to have sex with defendant Epstein. Defendants Maxwell, and Epstein each fraudulently promised plaintiff again that her sexual compliance would be

Honor. Laura Menninger, on behalf of Ghislaine Maxwell, from Haddon Morgan & Foreman. MR. LORENZO: Good afternoon, your Honor. Alex Lorenzo from Alston & Bird. As Mr. Miller indicated, we are now predecessor counsel. I saw the order pop on the docket. wanted to come down in case that there was some issue,

stein's case. I have also poured over hundreds of stories. As you are aware, many of those stories as well as several lawsuits -- allege that you, Ghislaine Maxwell and others -- were involved in a sex- trafficking operation involving underage girls. I am offering you the opportunity to discuss anything you like

s several lawsuits -- allege that you, Ghislaine Maxwell and others -- were involved in a sex- trafficking

as well as several lawsuits -- allege that you, Ghislaine Maxwell and others -- were involved in a sex- tra

iami Heralb 3511 NV1' 91 Avcntiv, Miami. Fl, 33172 October 30, 2018 c/o John E. Stephenson Jr. Alston & Bird One Atlantic Center 1201 W. Peachtree St. Altanta, GA 30309 Sent Via Certified Mail Dear Ms. www.miamiherald.com I am sending this letter to g

PO BoX 775392 Chicago, IL 60677-5392 MEMO Account # 81115562 NES LLC 2/9/2018 1038 S R100 LO 313v I:02 100 10 3 31: OS Hai 295370711' SDNY GM 00051126 _ _ DB-SDNY-0013950 p z L1.1 Zrt. (..16 cd O a. a. O EFTA_00161734 EFTA01293140 •• ,•• .-• •,-1 orerp.- % • • V.: zimo..)0

00/100”*"**".* ** **** * litt annar"*""""* ************** *******"*"*"*""""*""*" $ *4100,000.00 Mats C ee'e/it.t 0 IS? (1.9; etfciteet. ; 1(1.0 Alston & Bird. • One Atlantic Center 1201 W Peachtree St Atlanta, GA 30309-3424 Attn: John Stephenson FereG avid ght;th firreol l tet eA 4k•-ca( .A_ JAY/