Epstein Secrets

cts, for your contention that statements made by Ms. Maxwell or her agent were non-defamatory statements of fa

United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT GHISLAINE MAXWELL Plaintiff, by and through her undersigned counsel, hereby pro

strict of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT GHISLAINE MAXWELL Plaintiff, by and through her undersigned counsel, hereby propounds Plaintiff's First Set of Interrogatories to Defendant Ghislaine Maxwell

New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT GHISLAINE MAXWELL Plaintiff, by and through her undersigned counsel, hereby propounds Plaintiff's First Set of Interrogatories to Defendant Ghislaine Maxwell, pursua

les 26 and 33 of the Federal Rules of Civil Procedure and Local Rule 33. The responses are due at the offices of Boies, Schiller & Flexner LLP, 401 East Las Olas Boulevard, Suite 1200, Fort Lauderdale, Florida 33301, within thirty (30) days of service hereof. DEFINITIONS Wherever they hereafter appear the following w

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 IN LIMINE TO EXCLUDE IN TOTO CERTAIN DEPOSITIONS DESIGNATED BY PLAIN

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 IN LIMINE TO EXCLUDE IN TOTO CERTAIN DEPOSITIONS DESIGNATED BY PLAINTIFF FOR

Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 EFTA00595612 Defendant Ghislaine Maxwell ("Ms. Maxwell") files her Reply in Support of the Motion in Limine to Exclude In Toto certain depositions designated by Plaintiff for use at trial a

203 EFTA00595612 Defendant Ghislaine Maxwell ("Ms. Maxwell") files her Reply in Support of the Motion in Li

ollowing: Sigrid S. McCawley Paul G. Cassell Meredith Schultz 383 S. University Street BOLES, SCHILLER & FLEXNER, LLP Salt Lake it UT 4112 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale FL 33301 Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2

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

wing: Sigrid S. McCawley Paul G. Cassell Meridith Schultz 383 S. University Street BOIES, SCHILLER & FLEXNER, LLP Salt Lake City, UT 84112 401 East Las Olas Boulevard, Ste. 1200 [email protected] Ft. Lauderdale, FL 33301 [email protected] [email protected] Bradley J. Edwards FARMER, JAFFE, WEISSING,

ct after they left and before 17 they went to bed. 18 Q. Was there anyone else who assigned your wife 19 work other than you? 20 A. No. Ms. Maxwell, sometimes she would tell my 21 wife, go buy some stuff, go get this and go get that. 22 She was mostly -- my wife was mostly out of the house.

s room or I will ask him, where you want to 13 set the massages? He will told me, set in the blue room 14 and set them in my room. Or set them in Ghislaine's 15 room and the red room, depends on who people were there. 16 But there were times where two of the girls at the same 17 time, yes. 18 Q.

's -- Dr. Eva 3 Anderson was no longer Mr. Epstein's girlfriend, -- 4 A. That's correct. 5 Q. -- and a new girlfriend came in and that was 6 Ghislaine Maxwell? 7 A. That's correct. 8 Q. And when Ms. Maxwell came in, she, in essence, 9 took over as your immediate supervisor? 10 A. That's correct.

your wife 19 work other than you? 20 A. No. Ms. Maxwell, sometimes she would tell my 21 wife, go buy so

2 Page 82 1 APPEARANCES: On behalf of the Plaintiffs: 4 5 6 7 8 9 10 11 WILLIAM J. BERGER, ESQUIRE ROTHSTEIN ROSENFELDT ADLER 12 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, Florida 33301 13 RICHARD WILLITS, ESQUIRE RICHARD H. WILLITS, P.A. 2290 10th Avenue North, Suite 404 ' 461 STUAR

ct after they left and before 17 they went to bed. 18 Q. Was there anyone else who assigned your wife 19 work other than you? 20 A. No. Ms. Maxwell, sometimes she would tell my 21 wife, go buy some stuff, go get this and go get that. 22 She was mostly -- my wife was mostly out of the house.

s room or I will ask him, where you want to 13 set the massages? He will told me, set in the blue room 14 and set them in my room. Or set them in Ghislaine's 15 room and the red room, depends on who people were there. 16 But there were times where two of the girls at the same 17 time, yes. 18 Q.

's -- Dr. Eva 3 Anderson was no longer Mr. Epstein's girlfriend, -- 4 A. That's correct. 5 Q. -- and a new girlfriend came in and that was 6 Ghislaine Maxwell? 7 A. That's correct. 8 Q. And when Ms. Maxwell came in, she, in essence, 9 took over as your immediate supervisor? 10 A. That's correct.

your wife 19 work other than you? 20 A. No. Ms. Maxwell, sometimes she would tell my 21 wife, go buy so

A. 8 18205 Biscayne Boulevard, Suite 2218 Miami, Florida 33160 9 Phone: 10 11 WILLIAM J. BERGER, ESQUIRE ROTHSTEIN ROSENFELDT ADLER 12 401 East Las Olas Boulevard, Suite 1650 Fort Lauderdale, Florida 33301 13 Phone: 14 15 KATHERINE W. EZELL, ESQUIRE PODHURST ORSECK, P.A. 16 25 West Flagler Street, Suit

tle 243 Riverside, Dr. New York, NY 10025 141' Ghislaine Maxwell Address Currently Unknown 142 Records Custodia

iverside, Dr. New York, NY 10025 141' Ghislaine Maxwell Address Currently Unknown 142 Records Custodia

tle 243 Riverside, Dr. New York, NY 10025 141' Ghislaine Maxwell Address Currently Unknown 142 Records

various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages. 13 Charles Lichtman, Esquire 350 East Las Olas Boulevard I Suite 1000 Fort Lauderdale, FL 33301 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. W

United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT GHISLAINE MAXWELL Plaintiff, by and through her undersigned counse

intiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT GHISLAINE MAXWELL Plaintiff, by and through her undersigned counsel, hereby propounds Plaintiff's First Request for Production of Documents pursuant to Rules 26 and

each Florida between the years 1999 and 2002. DOCUMENT REOUEST NO. 36 All documents you rely upon to establish that (a) sworn allegations "against Ghislaine Maxwell are untrue." (b) the allegations have been "shown to be untrue."; and (c) "claims are obvious lies." DOCUMENT REQUEST NO. 37 All document

the Federal Rules of Civil Procedure to the Defendant Ghislaine Maxwell. The responses are due at the offices of Boies, Schiller & Flexner LLP, 401 East Las Olas Boulevard, Suite 1200, Fort Lauderdale, Florida 33301, within thirty (30) days of service hereof. DEFINITIONS Wherever they hereafter appear the following w

Maxwell, including all Documents related to communications with Ghislaine Maxwell from 1999 — present. 8. All Documents relating to any members of Ghislaine Maxwell's family, including all Documents related to communications with any members of Ghislaine Maxwell's family from 1970 — present. 9. All Documents re

ff" in the above captioned action shall mean the plaintiff formerly known as 4. "Defendant" in the above captioned action shall mean the defendant Ghislaine Maxwell and her employees, representatives or agents. 5. "Document" shall mean all written and graphic matter, however produced or reproduced, an

above captioned action shall mean the plaintiff formerly known as 4. "Defendant" in the above captioned action shall mean the defendant Ghislaine Maxwell and her employees, representatives or agents. 5. "Document" shall mean all written and graphic matter, however produced or reproduced, and each an

ey Epstein. INSTRUCTIONS 1. Production of Documents and items requested herein shall be made at the offices of Boies Schiller & Flexner, LLP, 401 East Las Olas Boulevard, Suite 1200, Fort Lauderdale, Florida 33301, no later than five (5) days before the date noticed for Your deposition, or, if an alternate date is a

Maxwell, including all Documents related to communications with Ghislaine Maxwell from 1999 — present. 8. All Documents relating to any members of Ghislaine Maxwell's family, including all Documents related to communications with any members of Ghislaine Maxwell's family from 1970 present. 9. All Documents rela

n the above captioned action shall mean the plaintiff formerly known asMIMI. 4. "Defendant" in the above captioned action shall mean the defendant Ghislainc Maxwell and her employees, representatives or agents. 5. "Document" shall mean all written and graphic matter, however produced or reproduced, an

captioned action shall mean the plaintiff formerly known asMIMI. 4. "Defendant" in the above captioned action shall mean the defendant Ghislainc Maxwell and her employees, representatives or agents. 5. "Document" shall mean all written and graphic matter, however produced or reproduced, and each an

rey Epstein. INSTRUCTIONS 1 Production of Documents and items requested herein shall be made at the offices of Soaks Schiller & Flexner, LLP, 401 East Las Olas Boulevard, Suite 1200, Port Lauderdale, Florida 33301, no later than five (5) days before the date noticed for Your deposition, or, if an alternate date is a

d 04/07/16 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. MOTION FOR ADMISSION PRO HAC VICE Pursuant to Rule 1.3 of the Local Rules of the United States Courts for the Southern and Eastern Di

intiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. MOTION FOR ADMISSION PRO HAC VICE

ffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. MOTION FOR ADMISSION PRO HA

2628 Email: [email protected] Email: [email protected] Attorneys for Defendant Meredith L Schultz BOIES, SCHILLER & FLEXNER LLP (FL) 401 East Las Olas Boulevard, Suite 1200 Fort Lauderdale, FL 33301 Telephone: (954)-356-0011 Facsimile: (954)456-0022 Email: [email protected] Paul G Cassell (Pro Hac Vice