Epstein Secrets

e.24h24/43134.01FrietibtOrtlefifitin0a0le28013,8111$2eafiabef146f 22 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Reply In Support Of Iler Objections to tnsealinu Sealed Materials Laura A. Menninger Jeffre

iabef146f 22 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Reply In Support Of Iler Objections to tnsealinu Sealed Materials Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C

ine Maxwell says she was Epstein's employee not his madam," MIAMI HERALD (Mar. 18, 2020) (quoting Sigrid McCawley, "It is absolutely appalling that Ghislaine Maxwell, who committed crimes with Epstein against these victims, is seeking to drain funds from the very estate that should be paying the Epstein victims'

ISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Reply In Support Of Iler Objections to tnsealin

it is hereby ORDERED AND ADJUDGED as follows: the Rule 21 Motion (DE 280) is DENIED; the Rule 15 Motion (DE 311) is DENIED; Intervenor Dershowitz's Motion for Limited Intervention (DE 282) and Motion for Leave to File Supplemental Reply in Support of Motion for Limited Intervention (DE 317) are DENIED AS MOOT; Petitioners' Mo

inister pattern — it is also worth noting that each of the other four individuals Jane Doe No. 3 identified by name in her motion (Jeffrey Epstein, Ghislaine Maxwell, Jean Luc Brunel, and Prince Andrew) have also all been afforded opportunities to explain themselves — and all four have declined to take them. Eps

After extensive discussion and coordinating a convenient time and place, as well as ultimately agreeing to a confidentiality agreement prepared by Maxwell's attorney, at the eleventh hour Maxwell's attorney informed the undersigned that Maxwell's mother was very ill and that consequently Maxwell was le

entified by name in her motion (Jeffrey Epstein, Ghislaine Maxwell, Jean Luc Brunel, and Prince Andrew) have

g "targeted" precisely because his involvement in Epstein's sexual trafficking would help "blow up" the plea agreement: 13 In his Supplement to his Motion for Limited Intervention, Dershowitz claims that only infonnation relevant to this case is information known by the Government before September 24, 2007 — the latest date o

f the enterprise with others, including Ghislane Maxwell and Jean Luc Brunel, to obtain minor girls not on

as part of the enterprise with others, including Ghislane Maxwell and Jean Luc Brunel, to obtain minor girl

mployees and underlings to repeatedly find and bring minor girls to him. Epstein worked in concert as part of the enterprise with others, including Ghislane Maxwell and Jean Luc Brunel, to obtain minor girls not only for his own sexual gratification, but also for the sexual gratification of others. The FBI deter

ust a few days ago your Office did not oppose a motion to intervene in the case by Alan Dershowitz. See DE 294 ("The Government does not oppose the Motion for Limited Intervention by Alan M. Dershowitz."). If your Office is not going to oppose a motion by a suspected co-conspirator of Epstein's to intervene in the case, we tr

ONLY EFTA00607277 60 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 you know, with Epstein, and with Maxwell , and those sorts of things. So you start to look at the flight logs and you see what's going on is not just events that are occurring in Florida

6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 spreading to Epstein's mansion in New York, it seems to be spreading to Ghislane Maxwell's flat in London, and -- and it goes on. So those are the kinds of things that would have formed the -- the -- the basis. Particularly when you sta

pstein, but other powerful persons, for example, Ghislane Maxwell is there with him on all of these flight

. SIMPSON: Q. Let me identify that for the record. I may want to mark two things. A. Okay. Q. Exhibit 1 is documented Plaintiff's Response to Motion for Limited Intervention by Alan M. Dershowitz, and I'm going to ask the reporter to mark another exhibit at the same time. This will be Exhibit 2, and this is a document

inister pattern — it is also worth noting that each of the other four individuals Jane Doe No. 3 identified by name in her motion (Jeffrey Epstein. Ghislaine Maxwell, Jean Luc Brunel, and Prince Andrew) have also all been afforded opportunities to explain themselves — and all four have declined to take them. Eps

ked questions about his sexual abuse of young girls. including Jane Doe No. I. Jane Doe No. 2, and Jane Doe No. 3. See generally Exhibit 16 at 1-7. Maxwell. In 2009, undersigned counsel (Brad Edwards) served Ghislaine Maxwell with a subpoena for a deposition in a civil case against Jeffrey Epstein. Afte

entified by name in her motion (Jeffrey Epstein. Ghislaine Maxwell, Jean Luc Brunel, and Prince Andrew) have

g "targeted" precisely because his involvement in Epstein's sexual trafficking would help "blow up" the plea agreement: 13 In his Supplement to his Motion for Limited Intervention, Dershowitz claims that only information relevant to this case is information known by the Government before September 24, 2007 — the latest date o

OO FF WwW NY =| NO RO PO PNP NM NO | S| S| HS SF S| S| S| S| S| non BP WO NO -|- ODO OO WDN OO OT BP WO NYO — 60 you know, with Epstein, and with Maxwell, and those sorts of things. So you start to look at the flight logs and you see what's going on is not just events that are occurring in Florida, bu

S| S| HS SF S| S| S| S| S| non BP WO NO -|- ODO OO WDN OO OT BP WO NYO — 62 spreading to Epstein's mansion in New York, it seems to be spreading to Ghislane Maxwell's flat in London, and -- and it goes on. So those are the kinds of things that would have formed the -- the -- the basis. Particularly when you start

Epstein, but other powerful persons, for example, Ghislane Maxwell is there with him on all of these flights

BY MR. SIMPSON: Q. Let me identify that for the record. I may want to mark two things. A. Okay. Q. Exhibit 1 is documented Plaintiff's Response to Motion for Limited Intervention by Alan M. Dershowitz, and I'm going to ask the reporter to mark another exhibit at the same time. This will be Exhibit 2, and this is a document ent