Epstein Secrets

20-2413-cv United States Court of Appeals for the Second Circuit VIRGINIA L GIUFFRE, —against- GHISLAINE MAXWELL, Plaintiff-Appellee, Defendant-Appellant. ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK 15-CV-74

s with the Government's position and opposes Defendant's motion to consolidate this appeal (the "civil appeal") with her appeal in United States v. Maxwell, No. 20-3061 (the "criminal appeal"). To the extent that Defendant's criminal appeal is not dismissed, Defendant's motion to consolidate should be

to one another. First, the issues presented in the criminal appeal have no bearing on the civil Citations to "D.E." refer to this Court's docket. Ghislaine Maxwell's Appendix is cited as "App." Virginia Giuffre's Supplemental Appendix is cited as "SA." EFTA00095336 appeal, and vice versa. As the Government's l

oad arguments lacking in specificity. App. 777 ("Ms. Maxwell's eleventh-hour request for reconsideration is de

ant to this Court's September 11, 2020, order directing the parties to respond to the Government's amicus letter brief filed on September 16, 2020. D.E. 113.1 Ms. Giuffre agrees with the Government's position and opposes Defendant's motion to consolidate this appeal (the "civil appeal") with her app

criminal appeals bearing no relation to one another. First, the issues presented in the criminal appeal have no bearing on the civil Citations to "D.E." refer to this Court's docket. Ghislaine Maxwell's Appendix is cited as "App." Virginia Giuffre's Supplemental Appendix is cited as "SA." EFTA00095

rrogatotics Subject matter: Investigator. 23. -friend of (Address will be provided upon receipt) Subject matter: Victim and friend of =. 24. Ghislane Maxwell c/o Ghislane Corp. 3580 Brillo Way Palm Beach, FL 33480 Subject matter: Associate of Epstein. 26. Parent Child Center West Palm Beach, FL Sub

t matter: Victim and friend of =. 24. Ghislane Maxwell c/o Ghislane Corp. 3580 Brillo Way Palm Beach,

) Subject matter: Victim and friend of =. 24. Ghislane Maxwell c/o Ghislane Corp. 3580 Brillo Way Palm

s extended. In light of Plaintiffs filing of her Conditional Notice of Intent to Exclusively Rely on Statutory Damages Provided by 18 U.S.C. §2255 (D.E. 113) on June 5, 2009, Plaintiff agrees to a modification of the pretrial schedule as outlined in Defendant EPSTEIN's Motion to Strike (D.E. 104); to

the Government's witness, subject, or tar et o Ghislaine Maxwell, ▪ Investigation Includi Larry Mo iso

cution/non-prosecution of Epstein; b) Attorney Bruce Reinhart's involvement in and/or awareness of the Government's witness, subject, or tar et o Ghislaine Maxwell, ▪ Investigation Includi Larry Mo iso i 1 ogers, r lam Hammond, and Robert Roxburgh; c) All documents, correspondence, and other information r

nment's witness, subject, or tar et o Ghislaine Maxwell, ▪ Investigation Includi Larry Mo iso i 1 oge

vilege log with its objections annotated (D.E. 224-1); (2) a motion to compel production of documents that are not privileged, numbering eight pages D.E. 225; (3) a twenty-four page, single-spaced affidavit of petitioners' counsel, addressing the EFTA00179785 Case 9:08-cv-80736-KAM Document 230 Ent

dent of Florida. 13440 This tax was received by GM FAXMakes fax server. For more information, visit

million - - well over the $75,000 amount-in-controversy requirement for diversity jurisdiction. See Jane Doe No. 2 at D.E. 1 ¶ 4; Jane Doe No. 3 at D.E. I ¶ 4; Jane Doe No. 4 at D.E. 1 ¶ 4; Jane Doe No. 5 at D.E. 1 ¶ 4. 3. There is complete diversity. Diversity jurisdiction requires complete divers

ourt of Appeal's controlling case of General Motors Corp v. McGee, 837 So. 2d 1010 (Fla. 4'h DCA 2002), Edwards is about to suffer the same fate as GM based on his Rule 1.280-noncompliant privilege log and the central issues to Edwards' lawsuit that the e-mails implicate. As the trial judge in the

ey." D.E. 1318 04/03/18 Edwards' Motion for Sanctions for Violation of Court Order (withdrawn) — quoting Epstein's statements: 6 EFTA00794303 D.E. I Date I Document ¶ 12 - "Second, the alleged eight-year-old "confidential" information to which Edwards refers is 47 exhibits comprised of a s