Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff Case No. 15-cv-07433-RWS v. HEARING REQUESTED Ghislaine Maxwell, Defendant JEFFREY EPSTEIN'S REPLY TO PLAINTIFF'S RESPONSE TO HIS MOTION TO QUASH TRIAL SUBPOENA Mr. Epstein respectfully requests that he be per

to repeat his assertion of his Fifth Amendment privilege. Second, plaintiff argues that Mr. Epstein should be required to appear because defendant Maxwell has objected to the use of Mr. Epstein's deposition testimony, claiming that he is not an unavailable witness. Response at 3. This is simply a non-i

Case No. 15-cv-07433-RWS v. HEARING REQUESTED Ghislaine Maxwell, Defendant JEFFREY EPSTEIN'S REPLY TO P

intiff's case in chief. Nor does speculation that Ms. Maxwell might object to the authenticity of the "blackbo

2 EFTA00589511 United States v. Bahadar, 954 F.2d 821, 827 (2d Cir. 1992), quoting Salerno, 937 F.2d 797, 805 (2d Cir. 1991). See, e.g., Davis v. Velez, 797 F.3d 192, 202-03 (2d Cir. 2015)(no abuse of discretion in finding witness unavailable where attorney had represented to court that client woul

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL'S REPLY IN SUPPORT OF HER MOTIONS IN LIMINE Jeffrey S. Pagliuca Laura A. Menninger

ES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL'S REPLY IN SUPPORT OF HER MOTIONS IN LIMINE Jeffrey S. Pagliuca Laura A. Menninger HADDON MORGAN & FOREMAN P.C. Denver Phone: Christian R. Eve

INE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL'S REPLY IN SUPPORT OF HER MOTIONS IN LIMINE Jeffr

ruling on the admissibility for two weeks. 15 Ms. Maxwell reiterates her re, uest to defer III. THIS COUR

2d 266 (S.D.N.Y. 2007) 38 Townsend, No. Si 06 CR. 34 (JFK), 2007 WL 1288597 (S.D.N.Y. May I, 2007) 29, 36 Tracy, 12 F.3d 1186 (2d Cir.1993) 5 Velez, No. 3:10CR147 JBA, 2010 WL 4929266 (D. Conn. Nov. 30, 2010) 3 Vickers, 708 F. App'x 732 (2d Cir. 2017) 28, 31 Von Foelkel, 136 F.3d 339 (2d Cir.

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff Case No v. Ghislaine Maxwell, Defendant JEFFREY EPSTEIN'S REPLY TO PLAINTIFF'S RESPONSE TO HIS MOTION TO QUASH TRIAL SUBPOENA Far from being an "important witness," as plaint

to repeat his assertion of his Fifth Amendment privilege. Second, plaintiff argues that Mr. Epstein should be required to appear because defendant Maxwell has objected to the use of Mr. Epstein's deposition testimony, claiming that he is not an unavailable witness. Response at 3. This is simply a non-i

ERN DISTRICT OF NEW YORK Plaintiff Case No v. Ghislaine Maxwell, Defendant JEFFREY EPSTEIN'S REPLY TO P

intiff's case in chief. Nor does speculation that Ms. Maxwell might object to the authenticity of the "blackbo

-incrimination." United States v. Bahadar, 954 F.2d 821, 827 (2d Cir. 1992), quoting Salerno, 937 F.2d 797, 805 (2d Cir. 1991). See, e.g., Davis v. Velez, 797 F.3d 192, 202-03 (2d Cir. 2015)(no abuse of EFTA00585748 discretion in finding witness unavailable where attorney had represented to court th

lenge should be dismissed." Lord Justice Bean and Mr Justice Lewis "are expected to deliver a ruling in the near future." CRIMINAL INVESTIGATIONS Ghislaine Maxwell Reportedly Refuses To Reveal Name Of Spouse To FBI. The London (UK) Evening Standard (7/15, Somerville, 856K) reports, "Ghislaine Maxwell is secret

to charges she had trafficked at least three underage girls for billionaire paedophile Jeffrey Epstein." Assistant US Attorney Alison Moe "revealed Maxwell had a spouse while questioning who would co-sign her bond at a bail hearing in New York. She told the courthouse late on Tuesday: 'In addition to fa

dges' Inquest Ruling. CRIMINAL INVESTIGATIONS • Ghislaine Maxwell Reportedly Refuses To Reveal Name Of Spou

prison if convicted, according to a statement from the U.S. attorney's office. Federal prosecutors contend that Valladres was hired as 'muscle' and Velez to be the driver of a minivan in the July 16, 2018, kidnapping of Ruochen 'Tony' Liao from a mall parking lot in suburban San Gabriel. Valladares t

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

A was enacted in December 2008, after the events alleged in the FAC had occurred and it has no application to the allegations set forth in the FAC. Velez v. Sanchez, 693 F.3d 308, 325 (2d Cir. 2012) ("there is a well-established presumption against the retroactive application of legislation, including

Epstein's victims, and information that would expose innocent individuals to "allegations of wrongdoing." The Daily Beast (07/06, Revell) added that Ghislaine Maxwell may be cooperating with the FBI to take down Epstein's elite collaborators in exchange for a reduced sentence. According to the article, Ma

ictims, and information that would expose innocent individuals to "allegations of wrongdoing." The Daily Beast (07/06, Revell) added that Ghislaine Maxwell may be cooperating with the FBI to take down Epstein's elite collaborators in exchange for a reduced sentence. According to the article, Maxwell is

the 15th Court of Appeals on Thursday. FBI Looking for Man Convicted in Beating of Girlfriend in Colorado Nearly 30 Years Ago KUSA (NBC-9) (07/05, Velez) reported that federal authorities are still looking for a man who has avoided prison time since fleeing a Colorado courtroom in 1999, after a jury

s was charged just weeks after General Motors Co. alleged that he received funds from Fiat Chrysler to place former UAW vice president Joe Ashton on GM's board. The accusations came as part of a lawsuit by GM alleging that Fiat Chrysler got better contracts than competing automakers by bribing unio

ilty to conspiracy to conduct enterprise affairs through a pattern of racketeering activity, more commonly referred to as RICO conspiracy.... Lopez- Velez was arrested and charged in December 2019, at which time he was a probationary member of the New EFTA00136579 Bedford Chapter of the Latin Kings,

was charged just weeks after General Motors Co. alleged that he received funds from Fiat Chrysler to place former UAW vice president Joe Ashton on GM's board. The accusations came as part of a lawsuit by GM alleging that Fiat Chrysler got better contracts than competing automakers by bribing union

771) reports Lopez-Velez, "accused of shooting a man in the back last year pleaded guilty today to a RICO charge in federal court in Boston." Lopez- Velez "was arrested back in December 2019 as part of Operation Throne Down, a major takedown of the Latin Kings in Massachusetts, Connecticut and Rhode Is

was charged just weeks after General Motors Co. alleged that he received funds from Fiat Chrysler to place former UAW vice president Joe Ashton on GM's board. The accusations came as part of a lawsuit by GM alleging that Fiat Chrysler got better contracts than competing automakers by bribing union

771) reports Lopez-Velez, "accused of shooting a man in the back last year pleaded guilty today to a RICO charge in federal court in Boston." Lopez- Velez "was arrested back in December 2019 as part of Operation Throne Down, a major takedown of the Latin Kings in Massachusetts, Connecticut and Rhode Is