Epstein Secrets

7433-RWS Document 189 Filed 06/06/16 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X INNIErt INIMINME, Plaintiff, v. GHISLATNE MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S RESPONSE IN OPPOSITION TO MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT Laura A. Menninger Jeffr

er Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. EFTA00097395 Case 1:15-cv-07433-RWS Document 189 Filed 06/06/16 Page 2 of 11 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Response in Opposition to Plaintiff's Motion to Exceed Presumptive Ten Deposition Limit, and states as follows: INTRODUC

9 Filed 06/06/16 Page 4 of 11 Plaintiff makes a bizarre argument that somehow this testimony can be used to create an adverse inference against Ms. Maxwell,2 despite the fact that Ms. Maxwell did not invoke the Fifth Amendment and she testified fully and answered every question posed to her with the only

cument 189 Filed 06/06/16 Page 2 of 11 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Response in Op

06/16 Page 2 of 11 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Response in Opposition to Plaintiff

ached by Ghislaine Maxwell," and continuing that "Maxwell persuaded Jane Doe 143 (who was only fifteen years old) to come to Epstein's mansion ..." Menninger Decl., N. A at 26-29. No amount of "circumstantial evidence" can overcome the fact that Ms. Maxwell's statement was correct and that statements in the Jo

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff. v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S OPPOSITION TO MESSRS. CASSELL AND EDWARDS' RENEWED MOTIONS TO APPEAR PRO HAC VICE Defendant G

E MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S OPPOSITION TO MESSRS. CASSELL AND EDWARDS' RENEWED MOTIONS TO APPEAR PRO HAC VICE Defendant Ghislaine Maxwell, by and through her attorneys, hereby submits the following opposition to Messrs. Cassell and Edwards' Renewed Motions to Appear Pro Hac Vice in th

them to you now. You should have them shortly." Id. At 5:49 p.m., Plaintiff's counsel sent a document with an unsent fax cover sheet, to which Ms. Maxwell's counsel requested to know "when these were filed with the Court." Id. Ms. McCawley, at 6:02 p.m. stated that she "gave it to staff for faxing and

ocument with an unsent fax cover sheet, to which Ms. Maxwell's counsel requested to know "when these were fil

Court," as referenced in Motion for Paul Cassell to Appear (Doc. #112), because defense counsel had not received any such supplemental materials. [Menninger Decl. Ex. A]. Ms. McCawley responded that her "staff is scanning them to you now. You should have them shortly." Id. At 5:49 p.m., Plaintiff's counsel se

Case 1:15-cv-07433-RWS Document 25 Filed 12/28/15 Page 1 of 13 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK Plaintiff, Ghislaine Maxwell, Defendant. Case No.: I5-cv-07433-RWS REPLY MEMORANDUM OF LAW IN SUPPORT OF DEFENDANT'S MOTION TO DISMISS COMPLAINT Laura A. Menninger HADDON,

INTRODUCTION ARGUMENT I. PLAINTIFF FAILED TO PLAUSIBLY PLEAD DEFAMATION A. Plaintiff Failed to Adequately Plead a Defamation Claim 1 B. Ms. Maxwell's Statement In Context Is Not Defamatory 3 II. MS. MAXWELL'S STATEMENTS ARE PROTECTED BY PRIVILEGE 6 A. Qualified Privilege May Form the Basis f

OR THE SOUTHERN DISTRICT OF NEW YORK Plaintiff, Ghislaine Maxwell, Defendant. Case No.: I5-cv-07433-RWS

ed to Adequately Plead a Defamation Claim 1 B. Ms. Maxwell's Statement In Context Is Not Defamatory 3 II.

concerning "numerous American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders." Menninger Decl., Ex. C at 5. Plaintiff's story is palpably incredible, as even Judge Marra suggested in his Order. In any event, New York courts uniformly agree g

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

threats to people on the telephone? MR. PAGLIUCA: Object to form and foundation. 3 EFTA00595615 THE WITNESS: Yes. He wasn't always friendly See Menninger Decl., Ex. F, 10:6-14; 43:15-44:4 As explained in in Wright & Miller, Federal Practice and Procedures, the use of a document during testimony to refresh

1 of 37 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X VIRGINIA L. GUIFFRE, Plaintiff, 15 Civ. 7433 (RWS) - against - OPINION GHISLAINE MAXWELL, Defendant. X APpEARANCE S: Counsel for Plaintiffs BOEIS, SCHILLER & FLEXNER LLP 401 East Las Olas Boulevard, Suite 1200 Fort Lauderd

07433-RWS Document 135 Filed 05/02/16 Page 2 of 37 Sweet, D.J. Plaintiff Virginia Giuffre ("Giuffre" or "Plaintiff") has moved to compel Defendant Ghislaine Maxwell ("Maxwell" or "Defendant") to produce documents withheld on the grounds of privilege.- !lased on the conclusions set forth below, the motion is gr

35 Filed 05/02/16 Page 2 of 37 Sweet, D.J. Plaintiff Virginia Giuffre ("Giuffre" or "Plaintiff") has moved to compel Defendant Ghislaine Maxwell ("Maxwell" or "Defendant") to produce documents withheld on the grounds of privilege.- !lased on the conclusions set forth below, the motion is granted in p

d NY law." Privilege Log at 1. Defendant argues "Ms. Maxwell's communications with Mr. Barden should be const

ty participated in this email 19 EFTA R1 00011995 EFTA01734205 Case 1:15-cv-07433-RWS Document 125 Mled O5/02i16 Page 20 of 31 correspondence." Menninger Decl. 1 117 Supp. Reply at 5 n.2, Documents .11045-46 contain communications between Defendant and Barden; however, documents 81047-51 -include Gow (and