Epstein Secrets

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

depends on the diligence of the moving party."); Perfect Pearl Co., Inc. v. Majestic Pearl & Stone, Inc., 889 F. Supp. 2d 453, 457 (S.D.N.Y. 2012) (Engelmeyer, J.) ("To show good cause, a movant must demonstrate that it has been diligent, meaning that, despite its having exercised diligence, the applicable

re deeply concerning," and said he was demanding "a thorough investigation." In the aftermath of Epstein's apparent suicide, his alleged "recruiter" Ghislaine Maxwell now finds herself under the microscope. Geoffrey Berman, the U.S. attorney for the Southern District of New York, has vowed to continue the invest

criminal justice system, his alleged "co-conspirators" do not enjoy a similar reprieve. EFTA00040364 Several of Epstein's accusers have pointed to Maxwell as playing a pivotal role in enlisting his victims, according to thousands of pages of court documents unsealed on Friday -- just hours before Epste

stein's apparent suicide, his alleged "recruiter" Ghislaine Maxwell now finds herself under the microscope.

he carried for the gang. But he still participated in the gang's violent activity. "You appear to have learned a very hard lesson a very hard way," Engelmeyer said. Walter could be out of jail in three years with good behavior, authorities said. Sapone said Walter joined the entourage to work for Tekashi,

re deeply concerning," and said he was demanding "a thorough investigation." In the aftermath of Epstein's apparent suicide, his alleged "recruiter" Ghislaine Maxwell now finds herself under the microscope. Geoffrey Berman, the U.S. attorney for the Southern District of New York, has vowed to continue the invest

e grip of the criminal justice system, his alleged "co-conspirators" do not enjoy a similar reprieve. Several of Epstein's accusers have pointed to Maxwell as playing a pivotal role in enlisting his victims, according to thousands of pages of court documents unsealed on Friday -- just hours before Epste

stein's apparent suicide, his alleged "recruiter" Ghislaine Maxwell now finds herself under the microscope.

he carried for the gang. But he still participated in the gang's violent activity. "You appear to have learned a very hard lesson a very hard way," Engelmeyer said. Walter could be out of jail in three years with good behavior, authorities said. Sapone said Walter joined the entourage to work for Tekashi,

stein's apparent suicide, his alleged "recruiter" Ghislaine Maxwell now finds herself under the microscope.

re deeply concerning," and said he was demanding "a thorough investigation." In the aftermath of Epstein's apparent suicide, his alleged "recruiter" Ghislaine Maxwell now finds herself under the microscope. Geoffrey Berman, the U.S. attorney for the Southern District of New York, has vowed to continue the invest

e grip of the criminal justice system, his alleged "co-conspirators" do not enjoy a similar reprieve. Several of Epstein's accusers have pointed to Maxwell as playing a pivotal role in enlisting his victims, according to thousands of pages of court documents unsealed on Friday -- just hours before Epste

he carried for the gang. But he still participated in the gang's violent activity. "You appear to have learned a very hard lesson a very hard way," Engelmeyer said. Walter could be out of jail in three years with good behavior, authorities said. Sapone said Walter joined the entourage to work for Tekashi,