Epstein Secrets

06/16 Page 3 of 15 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Reply In Support of her Motion to C

Case 1:15-cv-07433-RWS Document 191 Filed 06/06/16 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff. v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S REPLY IN SUPPORT OF MOTION TO COMPEL NON-PRIVILEGED DOCUMENTS Laura A. Menninger Jeffrey S.

ent With Her Own Attorneys 10 CERTIFICATE OF SERVICE 13 EFTA00618133 Case 1:15-cv-07433-RWS Document 191 Filed 06/06/16 Page 3 of 15 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Reply In Support of her Motion to Compel Non-Privileged Documents contained on Plaintiff's Privilege Log, stating as foll

ys 10 CERTIFICATE OF SERVICE 13 EFTA00618133 Case 1:15-cv-07433-RWS Document 191 Filed 06/06/16 Page 3 of 15 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Reply In Support of her Motion to Compel Non-Privileged Documents contained on Plaintiff's Privilege Log, stating as follows: INTRODUC

, 2016 and dated in a manner to attempt to justify the privilege claim. A similar undated letter was invented for Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman (FJW), P.L, and co-counsel, Paul G. Cassell, Esq. Menninger Decl., Ex. L. It states: Again, while the letter is conveniently and purposeful

want to begin by asking you please to tell us about the circumstances of your first meeting Mr. Epstein. V: Ok. I was introduced to Mr. Epstein by Ghislaine Maxwell. I was working at Donald Trump's spa in Mar-a-Lago and I was prompted by Ghislaine to come to Jeffrey's mansion in Palm Beach that afternoon after

Mr. Epstein. V: Ok. I was introduced to Mr. Epstein by Ghislaine Maxwell. I was working at Donald Trump's spa in Mar-a-Lago and I was prompted by Ghislaine to come to Jeffrey's mansion in Palm Beach that afternoon after work to make some extra money and to learn about massage. She met me at the spa, an

Ok. I was introduced to Mr. Epstein by Ghislaine Maxwell. I was working at Donald Trump's spa in Mar-a-La

here, where was here? V: On the island. JS: When you were present with Jeffrey Epstein and Bill Clinton on the island, who else was there? V: Ghislaine, M, and there was 2 young girls that I could identify. I never really knew them well anyways. It was just 2 girls from New York. JS: And were all of

.A. 250 Australian Avenue South, Suite 1400 West Palm Beach. FL 33401 Phon Fax: Attorneys for Jeffrey Epstein Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phon Fax: Attorneys for Jeffrey Epstein Jose h L. Ackerman Jr., Esquire

want to begin by asking you please to tell us about the circumstances of your first meeting Mr. Epstein. V: Ok. I was introduced to Mt Epstein by Ghislaine Maxwell. I was working at Donald Trump's spa in Mar-a-Lago and I was prompted by Ghislaine to come to Jeffrey's mansion in Palm Beach that afternoon afte

g Mr. Epstein. V: Ok. I was introduced to Mt Epstein by Ghislaine Maxwell. I was working at Donald Trump's spa in Mar-a-Lago and I was prompted by Ghislaine to come to Jeffrey's mansion in Palm Beach that afternoon after work to make some extra money and to learn EFTA01657685 about massage. She met

: Ok. I was introduced to Mt Epstein by Ghislaine Maxwell. I was working at Donald Trump's spa in Mar-a-L

250 Australian Avenue South, Suite 1400 EFTA01657683 West Palm Beach, FL 33401 Attorneys for Jeffrey Epstein Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 FPax ho:nli Attorneys for Jeffrey Epstein Jose h L. Ackerman, Jr., Esquire

that if anything ever happened between Jeffrey and I, that I would have to sign my child over to him basically and that the child would be his and Ghislaine's, and I would be looking after it as long as nothing happened between Jeffrey and I. So, I was kind of freaked out by all of that. I pushed Jeffrey

, P.A. Suffolk, MA 02116 Attorneys for Jeffrey Epstein West Palm Beach, FL 33401 Attorneys for Jeffrey Epstein Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein Joseph L. Ackerman, Jr., Esquire Fowler White Burnett, P.A. West Palm Beach.

that if anything ever happened between Jeffrey and I, that I would have to sign my child over to him basically and that the child would be his and Ghislaine's, and I would be looking after it as long as nothing happened between Jeffrey and I. So, I was kind of freaked out by all of that. I pushed Jeffrey

OOOCMBAG Notice of Filing Supplement COUNSEL LIST Jack A. Goldberger, Esquire [email protected]; 7 .7 r Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 49S N A nrIrewe Avitmius quite 9 Attorneys for Jeffrey Epstein Joseph L. Ackerman, Jr., Esquire [email protected] Fowler White B

bmitted an affidavit (substantially similar to the affidavits submitted in support of the instant motion) in which he attested that he was hired by GM with the understanding that communications would be protected by the attorney-client privilege, that he was retained to perform work in anticipation

- 80232, 08-80380, 08-80381, 08-80993, 08- 80994 C. Josefsberg, Esq. Katherine W. Ezell, Esq. 7 Edwards, Esq. Farmer , Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 Phone: 954-524-2820 Fax: 954-524-2822 Counsel for Plaintiff in Related Cas

TION OF DEPOSITION PLEASE TAKE NOTICE that the undersigned attorneys cancel the deposition of: NAME ANDADDRESS DATE AND TIME LOCATION GI t.slame Maxwell January 23, 2012 Location to be determined h 10:00 a.m. New York City, NY I HEREBY CERTIFY that a true and correct copy of the foregoing has be

P.A. 250 Australian Avenue South, Suite 1400 ; Viit Palm Beach, FL 33401 e: (561)-659-8300 Fax: (561)435-8691 Fa4mer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 42N. Andrews Avant; Suite 2 Fot Lauderdale, FL 33301 Phone: (954)424-2820 Fax: (954)-524-2822 COUNSEL LIST Joseph L. Ackerman, Jr.