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

.com jpagliucemflaw.com [email protected] By: /s Sigrid McCawley Sigrid McCawley (Admitted Pro Hac Vice) Meredith Schultz (Admitted Pro Hac Vice) Boles Schiller Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 19 EFTA00792774

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

enver, Colorado 80203 Tel: Fax: Email: By: /s Sigrid McCawley Sigrid McCawley (Admitted Pro Hac Vice) Meredith Schultz (Admitted Pro Hac Vice) Boles Schiller Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 19 EFTA00617414

na to Testify at a Deposition in a Civil Action UNITED STATES DISTRICT COURT for the Southern District of New York Plaintiff v. Jeffre Epstein, Ghislaine Maxwell and To: Lesley Groff Defendant Civil Action No. 17-cv-00616 (JGK) SUBPOENA TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION Igor Zlnoviev (Name

ew York Plaintiff v. Jeffre Epstein, Ghislaine Maxwell and To: Lesley Groff Defendant Civil Action

trict of New York Plaintiff v. Jeffre Epstein, Ghislaine Maxwell and To: Lesley Groff Defendant Civil

s, e-mail address, and telephone number of the attorney representing (name of pony) , who issues or requests this subpoena, are: Sigrid McCawley, Boles Schiller Flexner LLP, 401 E. Las Olas Boulevard Suite 1200, Fort Lauderdale, FL 33301, E-mail: , Telephone: Notice to the person who issues or requests this subpoena

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. No. 17 Civ. 00616 (JGK) JEFFREY EPSTEIN, GHISLAINE MAXWELL, pi...LESLEY GROFF and SHEV, Defendants. PLAINTIFF'S RE-NOTICE OF TAKING VIDEOTAPED DEPOSITION OF GHISLAINE MAXWELL PLEASE TAKE NOTICE

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. No. 17 Civ. 00616 (JGK) JEFFREY EPSTEIN, GHISLAINE MAXWELL, pi...LESLEY GROFF and SHEV, Defendants. PLAINTIFF'S RE-NOTICE OF TAKING VIDEOTAPED DEPOSITION OF GHISLAINE MAXWELL PLEASE TAKE NOTICE THAT, pu

30 of the Federal Rules of Civil Procedure, counsel for Plaintiff, will take a videotaped deposition of the Defendant as set forth below: NAME: Ghislaine Maxwell DATE AND TIME: October 15, 2018 at 10:00 a.m. LOCATION: Boies Schiller Flexner LLP 575 Lexington Avenue, 7th Floor New York, NY 10022 The vide

0 Dated: September 26, 2018. BOLES SCHILLER FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boles Schiller Flexner LLP Bradley J. Edwards, Esq. (Admitted Pro Hac Vice) Stanley Pottinger, Esq. Paul G. Cassell (Admitted Pro Hac Vice) S.J. Quinney College of Law niv

By 2021, our firms had successfully brought lawsuits against Epstein himself during his life, his estate after his death, certain collaborators like Ghislaine Maxwell, and certain participants like Prince Andrew. Although we had collectively recovered substantial amounts for our clients, we believed they had not

ove, Ms. McCawley has devoted years of her career to advocating on behalf of survivors of Jeffrey Epstein, including in cases against Prince Andrew, Ghislaine Maxwell, and the Epstein Estate. Ms. McCawley was recognized by Forbes Magazine for her "iron clad interrogation skills" during the deposition of G

Cawley has devoted years of her career to advocating on behalf of survivors of Jeffrey Epstein, including in cases against Prince Andrew, Ghislaine Maxwell, and the Epstein Estate. Ms. McCawley was recognized by Forbes Magazine for her "iron clad interrogation skills" during the deposition of Ghislaine

1-1 Filed 06/22/23 Page 37 of 38 Email: [email protected] Email: [email protected] Sigrid McCawley (pro hac vice) Daniel Crispin (pro hac vice) Boles Schiller Flexner LLP 401 E. Las Olas Blvd. Suite 1200 Fort Lauderdale, FL 33316 Telephone: (954) 356-0011 Fax: (954) 356-0022 Email: [email protected] Email: dcr

s, servers, and personal electronic devices, whether in the United States or any foreign jurisdiction. 3. The "Litigation" means the case captioned M. Maxwell, 15 Civ. 7433 (RWS), in the Southern District of New York 4. Where possible, please produce the records requested herein in electronic form (native

3. The "Litigation" means the case captioned M. Maxwell, 15 Civ. 7433 (RWS), in the Southern District of

orney Southern District of New York The Silvio J. Mono Building One Saint Andrew's Plaza Neu• York, Neu• York 10007 February 5, 2019 VIA EMAIL Boles Schiller Flexner LLP 575 Lexington Avenue New York, NY 10022 Re: Grand Jury Subpoena Please be advised that the accompanying grand jury subpoena has been issued in

has filed an application for modification of a March 18, 2016 pretrial protective order, entered by the late Hon. in a civil defamation action, v. Maxwell, No. 15-cv-7433 (S.D.N.Y.) ("the Action"), in order to permit the law firm of Boles Schiller Flexner LLP ("Boies Schiller") to comply with a grand

ith a grand jury subpoena. The application is granted. I. Background A. The Protective Order In September 2015, commenced a civil suit against Ghislaine Maxwell, alleging that Maxwell had defamed by stating that was not the victim of sex crimes perpetrated by, among others, Maxwell and Jeffrey Eps

, entered by the late Hon. in a civil defamation action, v. Maxwell, No. 15-cv-7433 (S.D.N.Y.) ("the Action"), in order to permit the law firm of Boles Schiller Flexner LLP ("Boies Schiller") to comply with a grand jury subpoena. The application is granted. I. Background A. The Protective Order In September 2015,