Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) REPLY MEMORANDUM OF LAW IN SUPPORT OF MS. MAXWELL'S MOTION TO DISMISS COUNTS FIVE AND SIX OF THE SUPERSED

ISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) REPLY MEMORANDUM OF LAW IN SUPPORT OF MS. MAXWELL'S MOTION TO DISMISS COUNTS FIVE AND SIX OF THE SUPERSEDING INDICTMENT BECAUSE THE ALLEGED MISSTATEMENTS ARE NOT PERJURIOUS AS A MATTER OF LAW Jef

elations with her, which he denies. Ms claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. Ghislaine Maxwell's original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appear

330 (AJN) REPLY MEMORANDUM OF LAW IN SUPPORT OF MS. MAXWELL'S MOTION TO DISMISS COUNTS FIVE AND SIX OF THE S

nninger HADDON MORGAN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine Maxwell II EFTA00097392 Certificate of Service I hereby certify that on March 15, 2021, I served by email, pursuant Rule 2(B) of the Court's individual pra

.N.Y. 2012) 7, 9 United States v. Earp, 812 F.2d 917 (4th Cir. 1987) 8 United States v. Edlind, 887 F.3d 166 (4th Cir. 2018) 8 United States v. Landau, 737 F. Supp. 778 (S.D.N.Y. 1990) 7 United States v. Lighte, 782 F.2d 367 (2d Cir.1986) 6 United States v. Litvak, 808 F.3d 160 (2d Cir. 2015)

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

to discovery, the Court must "credit a plaintiff's averments of jurisdictional facts as true." In re Magnetic Audiotape, 334 F.3d at 206; see also Landau v. New Horizon, No. 02 Civ. 6802, 2003 WL 22097989, at *3, (S.D.N.Y., Sept. 8, 2003). The plaintiff has done all she needs to do to plead personal

ssipative structure approach, presumably there is a negentropy flow associated with 'maintaining' the dissipative structure in its low entropy form; Maxwell's demon is continually at work narrowing the spread of the distribution. However if this negentropy flow is smaller than the entropy flow through t

distribution [Levy & Solomon 1996]. In contrast the Maxwell-Boltzmann distribution of a normal thermodynamic

ence. Over the last two hundred years physicists, chemists and engineers have proposed different quantities such as entropy, enthalpy, free energy, Landau potential, etc to deal with entropic calculations in different systems. This has been done primarily to make the sums add up in a meaningful way su

erski, "Supertwistors, massive superparticles and k-symmetry," JHEP 0901 (2009) 041 [arXiv:0808.2155 [hep-th]]. [160] S. Fedoruk and J. Lukierski, "Maxwell group and HS field theory," arXiv:1309.6878 [hep-th]. [161] S. Fedoruk and V. G. Zima, "Bitwistor formulation of massive spinning particle," hep- th

yet to be found. Another issue which should be addressed is that of the representations content of the SU(212) symmetry uncovered for the superfiag Landau model [9], within the study of quantum mechanics on super manifolds. Preliminary results indicate these are new types of short representations previ

Meissner and colleagues, explained by theorists Fritz and Heinz London two years later, which goes by the name the Meissner effect. As Faraday and Maxwell discovered sixty years earlier, electric charges respond in different ways to magnetic and electric fields. In par- ticular, Faraday discovered that

losely surround the negative charge, and so at a distance the physical effects of the initial negative charge are reduced. This meant, according to Landau, that the closer you get to an elec- tron, the larger its actual charge will appear. If we measure the electron charge to be some specific value at