Epstein Secrets

Denver. Colorado 80203 PH 303.831.7364 rx 303.832.2628 www.hmflaw.corn Imenningerathmflaw.com v. Darren K Indyke, et aL On behalf of defendant Ghislaine Maxwell, I write under Judge Schofield's Individual Rules and Procedures for Civil Cases III(A)(1) and this Court's Practices II(A) to request a pre-motion

articipate in the Program and accept payment will be required to release all former employees or potential indemnitees of the Estate, including Ms. Maxwell, from any and all claims or causes of action that concern acts of sexual abuse by Mr. Epstein. We understand that, if the Program is approved, it ma

v. Darren K Indyke, et aL On behalf of defendant Ghislaine Maxwell, I write under Judge Schofield's Individ

2 of 3 Hon. Debra Freeman May 13, 2020 Page 2 Ms. Maxwell has asserted her plan to undertake a vast, broa

64 rx 303.832.2628 www.hmflaw.corn Imenningerathmflaw.com v. Darren K Indyke, et aL On behalf of defendant Ghislaine Maxwell, I write under Judge Schofield's Individual Rules and Procedures for Civil Cases III(A)(1) and this Court's Practices II(A) to request a pre-motion conference concerning our anti

chard D. Kahn, & Ghislaine Maxwell, 19-10475-LGS-DCF Dear Judge Freeman: Pursuant to Individual Rule I.D, Plaintiff hereby responds to Defendant Ghislaine Maxwell's request for a pre-motion conference in connection with her anticipated motion to stay discovery in this matter. The Court should deny Maxwell's moti

aine Maxwell's request for a pre-motion conference in connection with her anticipated motion to stay discovery in this matter. The Court should deny Maxwell's motion for a pre-motion conference and deny her anticipated motion in its entirety because, as explained below, each of Maxwell's reasons for sta

18, 2020 v. Darren K. Indyke, Richard D. Kahn, & Ghislaine Maxwell, 19-10475-LGS-DCF Dear Judge Freeman:

the merits of Maxwell's motion to dismiss in her response to Maxwell's letter requesting a pre-motion conference on that motion. ECF No. 48. Judge Schofield's words at the pre-motion conference—in which she suggested that Maxwell's counsel not file a motion to dismiss—speak for themselves, and demonstrat

TE OF JEFFREY EDWARD EPSTEIN, and GHISLAINE MAXWELL, Defendants. Case No. 1:19-cv-10475-LGS-DCF PL

NEW YORK Plainta v. DARREN K. INDYKE and RICHARD D. KAHN in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, and GHISLAINE MAXWELL, Defendants. Case No. 1:19-cv-10475-LGS-DCF PLAINTIFF RESPONSES AND OBJECTIONS TO DEFENDANTS DARREN K. INDYKE AND RICHARD D. KAHN'S FIR

se to this interrogatory at a later date, Plaintiff may have communicated or interacted with the following individuals associated with Decedent: • Ghislaine Maxwell; • • Members of Decedent's house staff at 9 East 71st Street, New York, New York; and • Members of Decedent's house staff at 49 Zorro Ranch Road

addition to or different from those imposed by the Federal Rules of Civil Procedure, the Local Rules of the Southern District of New York, or Judge Schofield's or Judge Freeman's Individual Rules and Practices. 3. Any objection to any of the Interrogatories is not an admission that Plaintiff has any in