Epstein Secrets

S DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Plaintiff, v. GHISLAINE MAXWELL, Defendant. Before: 15 Civ. 7433 (RWS) Oral Argument New York, N.Y. March 31, 2017 12:08 p.m. HON. ROBERT W. SWEET, District Judge

provision? We're going to present to the jury it's Maxwell who got the benefit of the immunity provision. S

your Honor -- the first line, second sentence. "The allegations made by," and then it says Victoria , which is inaccurate by the drafter, "against Ghislaine Maxwell are untrue." And then it follows. But that is the backdrop to this. And she's responding to things about herself, not about anybody else that are

, advocacy statements by Kliman, such as calling Ms. Maxwell a perpetrator, someone he's never met before, bu

y. THE COURT: So problems enough I've got. MR. EDWARDS: I understand. I understand, your Honor. So at a time when Jeffrey Epstein is investigated, Ghislaine Maxwell is flying on his plane, she's vacationing with him. We have flight logs, we have photographs that were taken during that time. THE COURT: So what

LTZ, ESQ. S.J. QUINNEY COLLEGE OF LAW AT THE UNIVERSITY OF UTAH For Plaintiff BY: PAUL G. CASSELL, ESQ. FARMER, JAFFE, WEISSING, EDWARDS, FISTOS, LEHRMAN, P.L. Attorneys for Plaintiff BY: BRADLEY J. EDWARDS, ESQ. HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ

INATION BY 24 MR. BOIES: 25 Q. Good morning, Ms. Maxwell. When MAG NA 0 LEGAL SERVICES EFTA00083936 C

Confidential Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x Plaintiff, -against- GHISLAINE MAXWELL, Defendant. Case No.: 15-cv-07433-RWS **CONFIDENTIAL** x Continued Videotaped Deposition of GHISLAINE MAXWELL, the Defendant herein,

CES EFTA00083934 Confidential Page 3 1 2 THE VIDEOGRAPHER: This is DVD No. 3 1, Volume II, of the continued video 4 recorded deposition of Ghislaine Maxwell 5 in the matter against 6 Ghislaine Maxwell, in the United States 7 District Court, Southern District of New 8 York. 9 This deposition is

L: Paul Cassell, from 8 Salt Lake City, Utah, also representing 9 10 MR. PAGLIUCA: Jeff Pagliuca and 11 Laura Menninger, on behalf of Ms. 12 Maxwell. 13 And Ms. McCawley has also entered 14 the room, and we have an assistant from 15 Boies Schiller from the Fort Lauderdale 16 office here to

le, Florida 33301 MEREDITH SCHULTZ, ESQUIRE SIGRID McCAWLEY, ESQUIRE 9 SANDRA PERKINS, PARALEGAL 10 FARMER JAFFE WEISSING EDWARDS FISTOS & 11 LEHRMAN, 12 Fort Lauderdale, Florida 33301 BY: BRAD EDWARDS, ESQUIRE 13 14 PAUL G. CASSELL ES UIRE 15 at ace ity, to 16 J. STANLEY POTTINGER PLLC

vision? We're going to 5 present to the jury it's Maxwell who got the benefit of the 6 immunity provision

onor -- the first line, second sentence. "The 21 allegations made by," and then it says Victoria which 22 is inaccurate by the drafter, "against Ghislaine Maxwell are 23 untrue." And then it follows. But that is the backdrop to 24 this. And she's responding to things about herself, not about 25 anybody el

E COURT: So problems enough I've got. 3 MR. EDWARDS: I understand. I understand, your Honor. 4 So at a time when Jeffrey Epstein is investigated, Ghislaine 5 Maxwell is flying on his plane, she's vacationing with him. We 6 have flight logs, we have photographs that were taken during 7 that time. 8

vocacy 22 statements by Kliman, such as calling Ms. Maxwell a 23 perpetrator, someone he's never met before

7 S.J. QUINNEY COLLEGE OF LAW AT THE UNIVERSITY OF UTAH For Plaintiff 18 BY: PAUL G. CASSELL, ESQ. 19 FARMER, JAFFE, WEISSING, EDWARDS, FISTOS, LEHRMAN, P.L. Attorneys for Plaintiff 20 BY: BRADLEY J. EDWARDS, ESQ. 21 HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant 22 BY: JEFFREY S. P

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

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

ourt's direction. DATED: March 21.2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS. FIST LEHRMAN. P.L. and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah Attorneys for Jane Doe #1 and Jane Doe #2 40 EFT

le John G. Koeltl Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, NY 10007-1312 RE: Jane Doe 43 v. Jeffrey Epstein, Ghislaine Maxwell, et. Al Case No. No. 17 Civ. 00616 (JGK) Dear Judge Koeltl: This is a letter motion requesting permission for Plaintiff to telephonically appear f

2 RE: Jane Doe 43 v. Jeffrey Epstein, Ghislaine Maxwell, et. Al Case No. No. 17 Civ. 00616 (JGK) Dear J

10007-1312 RE: Jane Doe 43 v. Jeffrey Epstein, Ghislaine Maxwell, et. Al Case No. No. 17 Civ. 00616 (JGK)

nday, May 22, 2017, at 4:30pm. Thank you very much for your time and consideration. Very Truly Yours, FARMER, JAFFE, WEISSING, EDWARDS, FISTOS and LEHRMAN, PL Bradley J Edwards Bradley J. Edwards BJE:mwk EFTA00610145

of 31 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO.: 1:17-CV-00616 JANE DOE 43, Plaintiff, vs. JEFFREY EPSTEIN GHISLAINE MAXWELL, AND Defendants. / FIRST AMENDED COMPLAINT Plaintiff JANE DOE 43, by and through her undersigned counsel, for her claims against Defendants J

ts. / FIRST AMENDED COMPLAINT Plaintiff JANE DOE 43, by and through her undersigned counsel, for her claims against Defendants Jeffrey Epstein, Ghislaine Maxwell, , and , alleges upon personal knowledge with respect to her own acts and status, and upon personal knowledge, information and belief as to all o

6 JANE DOE 43, Plaintiff, vs. JEFFREY EPSTEIN GHISLAINE MAXWELL, AND Defendants. / FIRST AMENDED CO

trial by jury on all issues triable as of right by a jury. Dated: June 5, 2017. Respectfully Submitted, FARMER, JAFFE, WEISSING. EDWARDS, FISTOS, LEHRMAN,. 29 EFTA00615967 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 30 of 31 By: /s/ Bradley J. Edwards Bradley J. Edwards PRO HAC VICE

dersigned counsel, for her EFTA00615971 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 2 of 31 claims against Defendants Jeffrey Epstein, Ghislaine Maxwell, and alleges upon personal knowledge with respect to her own acts and status, and upon personal knowledge. information and belief as to all other

males for sexual purposes to his friends in order to secure social, business, and other contacts as well as other things of value. 14. 44:Defendant Maxwell was for decades the highest-ranking employee of the Defendants' sex trafficking venture and enterprise. She herself recruited young, including und

of 31 claims against Defendants Jeffrey Epstein, Ghislaine Maxwell, and alleges upon personal knowledge wi

all issues triable as of right by a jury. Dated: Januafy-26r 201-7-.June 5, 2017. Respectfully Submitted, FARMER. JAFFE. WaVING. EDWARDS. FISTOS, LEHRMAN, M. EFTA00616000 Case 1:17-cv-00616-JGK Document 45 Filed 06/05/17 Page 30 of 31 29 EFTA00616001 Case 1:17-cv-00616-JGK Document 45 Filed 06/0

on of the protective order entered in Giuffre v. Maxwell, No. 15 Civ. 7433 (RWS), any issues related to th

e Motion to Dismiss. EFTA00792777 Honorable John G. Koeltl July 17, 2017 Page 3 Very Truly Yours, FARMER, JAFFE, WEISSING, EDWARDS, FISTOS and LEHRMAN, PL Bradley J. BJE:mwk EFTA00792778 2502658500 TRANSACTION REPORT FAX( TX) P.01/01 JUL/17/2017/MON 11:09 AM 001 DATE JUL/17 START T. RE