Epstein Secrets

hem as friendly. In the summer of 2000, according to a deposition by Juan Alessi, who managed Mr. Epstein's house in Palm Beach, Alessi was driving Ghislaine Maxwell, Mr. Epstein's girlfriend, to Donald Trump's Mar-a-Lago EFTA00808056 resort, when they saw a girl walking from the main lobby toward the spa. Ms.

, Mr. Epstein's girlfriend, to Donald Trump's Mar-a-Lago EFTA00808056 resort, when they saw a girl walking from the main lobby toward the spa. Ms. Maxwell approached the girl, a sixteen year old named who was reading a book on anatomy and massage therapy. Ms. Maxwell informed her that she knew someb

THE PERIOD OF TIME WHEN HE KNEW I NEVER SAW A NUDE PERSON AT HIS HOME OR AROUND THE POOL. THE ONLY PEOPLE I EVER SAW AT HIS HOME WERE HIS STAFF, GHISLAINE MAXWELL, HIS ASSISTANT , HIS 20- SOMETHING YEAR OLD GIRLFRIEND AND SOME BUSINESS ACQUAINTANCES. I NEVER SAW ANYBODY CLOSE TO UNDER-AGE. I NEVER SA

girl walking from the main lobby toward the spa. Ms. Maxwell approached the girl, a sixteen year old named w

y to his island, which she did several times in late 2006 and early 2007. Mr. Epstein and Ms. Maxwell told they could help arrange her admission at the Fashion Institute of Technology, where she dreamed of studying. 50. was told that if she refused to have sex with Mr. Epstein and his associates, her apartment would be taken aw

hem as friendly. In the summer of 2000, according to a deposition by Juan Alessi, who managed Mr. Epstein's house in Palm Beach, Alessi was driving Ghislaine Maxwell, Mr. Epstein's girlfriend, to Donald Trump's Mar-a-Lago resort, when they saw a girl walking from the main lobby toward the spa. Ms. Maxwell approa

islaine Maxwell, Mr. Epstein's girlfriend, to Donald Trump's Mar-a-Lago resort, when they saw a girl walking from the main lobby toward the spa. Ms. Maxwell approached the girl, a sixteen year old named who was reading a book on anatomy and massage therapy. Ms. Maxwell informed her that she knew some

THE PERIOD OF TIME WHEN HE KNEW I NEVER SAW A NUDE PERSON AT HIS HOME OR AROUND THE POOL. THE ONLY PEOPLE I EVER SAW AT HIS HOME WERE HIS STAFF, GHISLAINE MAXWELL, HIS ASSISTANT , HIS 20- SOMETHING YEAR OLD GIRLFRIEND AND SOME BUSINESS ACQUAINTANCES. I NEVER SAW ANYBODY CLOSE TO UNDER-AGE. I NEVER SA

girl walking from the main lobby toward the spa. Ms. Maxwell approached the girl, a sixteen year old named

y to his island, which she did several times in late 2006 and early 2007. Mr. Epstein and Ms. Maxwell told they could help arrange her admission at the Fashion Institute of Technology, where she dreamed of studying. 50. was told that if she refused to have sex with Mr. Epstein and his associates, her apartment would be taken aw

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. 17 Civ. 616 (JGK) JEFFERY EPSTEIN, GHISLAINE MAXWELL, and Defendants. Before: x New York, N.Y. August 7, 2018 2:30 p.m. HON. JOHN G. KOELTL District Judge APPEARANCES BOIES SCHILLER &

ERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00285631 I877DOEC APPEARANCES (Continued) HADDON MORGAN & FOREMAN P.C. Attorneys for Defendant Ghislaine Maxwell BY: LAURA MENNINGER 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ALSO PRESENT: ALEXANDER LORENZO SOUTHERN DIS

mises made by the defendants, plaintiff returned to New York City, in the Southern District of New York, and was promptly ordered by the defendant Maxwell to have sex with defendant Epstein. Defendants Maxwell, and Epstein each fraudulently promised plaintiff again that her sexual compliance would be

again that her sexual compliance would be SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00285645 16 I877DOEC rewarded with admission to the Fashion Institute of Technology or a comparable college, a promise which they knew to be false." 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. No. 17 Civ. 00616 (JGK) JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROW and Defendants. PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANTS Plaintiff, by and through her undersign

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. No. 17 Civ. 00616 (JGK) JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROW and Defendants. PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANTS Plaintiff, by and through her undersigned couns

ies, e-mail, text, modem transmission, computer generated message, mail, personal delivery or otherwise. 3. "Defendants" shall mean the defendants Ghislaine Maxwell. Jeffrey Epstein. Lesley Groff, and 4. "Document" shall mean all written and graphic matter, however produced or reproduced, and each and every t

All Defendants) All documents evidencing money paid to at any time. DOCUMENT REQUEST NO. 6 (Directed to All Defendants) All documents relating to the Fashion Institute of Technology ("F.I.T."). 7 EFTA00793331 DOCUMENT REQUEST NO. 7 (Directed to All Defendants) All communications with F.I.T. related in any way to DOCUMENT RE

.D.N.Y. 2012) 11, 12 In re EPDM Antitrust Litt., 255 F.R.D. 308 (D. Conn. 2009) 12 Gambale v. Deutsche Bank AG, 377 F.3d 133 (2d Cir. 2004) v. Maxwell, No. 15 Civ. 7433, 2017 WL 1787934 (S.D.N.Y. May 3, 2017) 10, 11 10 Intl Equity Investments, Inc. v. Opportunity Equity Partners Ltd, No. 2010 W

THERN DISTRICT OF NEW YORK Plaintiff, —against— GHISLAINE MAXWELL, Defendant. 15 Civ. 7433 (RWS) MEMORANDUM OF L

THERN DISTRICT OF NEW YORK Plaintiff, —against— GHISLAINE MAXWELL, Defendant. 15 Civ. 7433 (RWS) MEMORAN

extravagant New York lifestyle, including a "massive" Upper East Side apartment, he failed to fulfill his alleged promise to "have her admitted" to the Fashion Institute of Technology ("FIT"). More than ten years later, based on these events, Jane Doe filed the original Complaint (and now the FAC) in which, astonishingly, she cla

n concerning possible victim of Jeffrey Epstein & Ghislaine Maxwell in New York, NY. Stein provided the fol

one number called the FBI National Threat Operations Center (NTOC) to report additional information concerning possible victim of Jeffrey Epstein & Ghislaine Maxwell in New York, NY. Stein provided the following information: Stein was a victim of Jeffrey Epstein & Ghislaine Maxwell, in NY in the mid 1990s. met

in New York, NY. Stein provided the following information: Stein was a victim of Jeffrey Epstein & Ghislaine Maxwell, in NY in the mid 1990s. met Maxwell and Epstein in approximately 1994. was a student at the Fashion Institute of Technology at NYC.= also worked at Henri Bendel at 5th Avenue, which

Stein was a victim of Jeffrey Epstein & Ghislaine Maxwell, in NY in the mid 1990s. met Maxwell and Epstein in approximately 1994. was a student at the Fashion Institute of Technology at NYC.= also worked at Henri Bendel at 5th Avenue, which was/is owned by the CEO of The Limited at the time. Stein met Maxwell as a client working

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JANE DOE 43, Plaintiff, VS. JEFFREY EPSTEIN, GHISLAINE MAXWELL, AND Defendants. CASE NO. 17 Civ 616 (JGK) MEMORANDUM OF LAW IN SUPPORT OF MOTION TO DISMISS EFTA00307096 ARGUMENT 1 A. Allegatio

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JANE DOE 43, Plaintiff, VS. JEFFREY EPSTEIN, GHISLAINE MAXWELL, AND Defendants. CASE NO. 17 Civ 616 (JGK) MEMORANDUM OF LAW IN SUPPORT OF MOTION TO DISMISS EFTA00307096 ARGUMENT 1 A. Allegations Regard

ns of fraud boil down to this: Epstein allegedly "confirmed to Plaintiff that he would use his wealth and influence to have Plaintiff admitted into the Fashion Institute of Technology" ("E") and to advanced her career, but had no intention of doing so. FAC ¶¶ 38, 53, 58-64. This is insufficient to satisfy Rule 9(b). First, the F

ere she held citizenship and where her parents resided, Epstein and Doc. # DC-1008444ki v.8 EFTA00298459 Brad Edwards, Esq. May , 2017 Page 6 Maxwell told her that "she would not be permitted to return to the United States to receive her promised education unless she lost weight." Plaintiff does n

ns of fraud boil down to this: Epstein allegedly "confirmed to Plaintiff that he would use his wealth and influence to have Plaintiff admitted into the Fashion Institute of Technology" ("E"), but had no intention of doing so. Cplt. ¶¶ 37, 50, 53-55. This is insufficient to satisfy Rule 9(b). First, the Complaint fails to identify