Epstein Secrets

me a summary-type statement detailing some of his anticipated testimony. Particularly, we need him to explain the role, if any, Alan Dershowitz and Ghislaine Maxwell played in either witnessing or participating in the sexual exploitation of minors. I look forward to your prompt reply. Sincerely, Didalad tut li

n the role, if any, Alan Dershowitz and Ghislaine Maxwell played in either witnessing or participating in

to explain the role, if any, Alan Dershowitz and Ghislaine Maxwell played in either witnessing or participa

LEONARD. JR .MMES PETER Late FMERTw PITCHER KATHLEEN SIMON SIEVE D. SMITH BO *0E S STARK RACIER A STEIN VIA EMAIL m i ONL November 10, 2015 Joe Titone, Esquire SEARCY DENNEY SCAROLA BARNHART el-SHIPLEY. Re: Edwards, Bradley vs. Dershowitz Our File No.: 20150013 Dear Mr. Titone: OIRLAHASSIS

10, 2015 Joe Titone, Esquire SEARCY DENNEY SCAROLA BARNHART el-SHIPLEY. Re: Edwards, Bradley vs. Dershowitz Our File No.: 20150013 Dear Mr. Titone: OIRLAHASSISOLEIDE; TOWLE HOUSE 517 NORTH CALHOUN STREET TALLAHASSEE. FL 32301-1231 I understand that you represent Jean Luc Brunel and further

ow 9 C. Jean Luc Brunel 10 D. Jeffrey Epstein 12 E. and 14 II. FIFTH AMENDMENT BY EPSTEIN, OR NOT ADMISSIBLE IN THIS CASE AGAINST MS. MAXWELL 15 III. PLAINTIFF'S BAD FAITH DISCOVERY TACTICS SHOULD NOT BE REWARDED WITH EXTRA TIME 18 1. Plaintiff's Rule 26 Revolving Door 18 2. Plainti

, 2014 WL 4354691, at *15 (S.D.N.Y. Sept. 2, 2014) 20 ii EFTA00605114 Case 1:15-cv-07433-RWS Document 228 Filed 06/20/16 Page 4 of 29 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Combined Response ("Response") in Opposition to Plaintiff's Motion to Extend Deadline to Complete Depositions ("Motion")

SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL. Defendant. X 15-cv-07433-RWS DEFENDA

PSTEIN, OR NOT ADMISSIBLE IN THIS CASE AGAINST MS. MAXWELL 15 III. PLAINTIFF'S BAD FAITH DISCOVERY TACTIC

-time deposition. Plaintiff first issued a Notice of a Rule 45 subpoena for documents from Mr. Brunel on February 16, at an address "c/o" attorney, Joe Titone. No documents were ever produced pursuant to that subpoena. Menninger Decl., Ex. F. Then, on May 23, 2016, Plaintiff issued a new "Notice of Subpoe

oe #3— leveled the allegations Tuesday against Harvard Law School professor Alan Dershowitz and Britain’s Prince Andrew, as well as British socialite Ghislaine Maxwell and French model scout Jean Luc Brunel. Dershowitz flatly denied the claims about him Wednesday in an interview with POLITICO. “Tt’s totally, unequi

ly false,” the celebrated attorney said. A spokesman for Prince Andrew denied the allegations Friday, while a lawyer who handled related matters for Maxwell did not respond to an e-mail seeking comment. Representatives of Brunel's modeling firm also did not reply to e-mail messages. The accusations came

ain’s Prince Andrew, as well as British socialite Ghislaine Maxwell and French model scout Jean Luc Brunel.

g that “Jane Doe #3 was forced to have sexual relations with this Prince when she was a minor in three separate geographical locations: in London (at Ghislaine Maxwell’s apartment), in New York, and on Epstein’s private island in the U.S. Virgin Islands (in an orgy with numerous other under-aged girls).” Previous pre

om: "Dr. Royce Jalazo" <[email protected]> To: [email protected] Sent: Tuesday, December 23, 2014 2:40:59 PM Subject: Jean Luc Brunel Mr. Titone, Please accept this email as my formal notification that Mr. Jean Luc Brunel attending an outpatient individual psychotherapy session with me on 12/

that "Jane Doe #3 was forced to have sexual relations with this Prince when she was a minor in three separate geographical locations: in London (at Ghislaine Maxwell's apartment), in New York. and on Epstein's private island in the U.S. Virgin Islands (in an orgy with numerous other under-aged girls)." Previous pr

y false." the celebrated attorney said. A spokesman for Prince Andrew denied the allegations Friday, while a lawyer who handled related matters for Maxwell did not respond to an e-mail seeking comment. Representatives of Bruncl's modeling firm also did not reply to e-mail messages. The accusations came

in's Prince Andrew, as well as British socialite Ghislaine Maxwell and French model scout Jean Luc Brunel.

: "Dr. Royce Jalazo" <[email protected]> To: [email protected] Sent: Tuesday, December 23, 2014 2:40:59 PM Subject: Jean Luc Brunel Mr. Titone, Please accept this e it al notification that Mr. Jean Luc Brunel attending an outpatient individual session with me on 12/12/14. Thank you, R