Epstein Secrets

/15 Page 1 of 29 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X PLAINTIFF, V. GHISLAINE MAXWELL, DEFENDANT. X 15-cv-07433-RWS GHISLAINE MAXWELL'S MEMORANDUM OF LAW IN SUPPORT OF MOTION TO DISMISS COMPLAINT Laura A. Menninger, Esq. HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Ave

r CO 80203 Tel: Dated: November 30, 2015 EFTA00595583 Case 1:15-cv-07433-RWS Document 15 Filed 12/01/15 Page 2 of 29 Table of Contents I. MS. MAXWELL'S STATEMENTS ARE PRIVILEGED 9 A. The Self-Defense Privilege Protects Ms. Maxwell's Statements 9 B. The Pre-Litigation Privilege Protects Ms. Maxw

attributed statement responds directly to allegations and claims made by Plaintiff. Compl. 1 31. Likewise to the extent the claimed statement that "Ghislaine Maxwell's original response to the lies and defamatory claims remains the same" (Compl. 1 32) refers to an earlier statement describing Plaintiff's "factual

led 12/01/15 Page 2 of 29 Table of Contents I. MS. MAXWELL'S STATEMENTS ARE PRIVILEGED 9 A. The Self-Defen

oot Camp, LLC, 813 F.Supp.2d 489, 550 (S.D.N.Y. 2011) 22 Sexier v. Warm/lash, P.C. v. Margrabe, 828 N.Y.S.2d 315 (1st Dep't 2007) 14 Shenkman v. O'Malley, 157 N.Y.S.2d 290, 297-98 (V' Dep't 1956) 8 Siegel v. Metropolitan Life Ins. Co., 32 N.Y.S.2d 658 (15` Dep't 1942) 8 Thai v. Cayre Group, Ltd., 7

her guests. approximately three year ago she met Ghislaine Maxwe Epstein through a mutuiiiiiiend. Epstein a

vestigation and I felt she may hav information pertaining to the case. During a sworn taped statement, stated she met Epstein three years ago when Ghaline Maxwell approached her while she was attending Palm Beach Atlantic College to work around Epstein's house. Maxwell had told her that they needed irls to w

et Epstein three years ago when Ghaline Maxwell approached her while she was attending Palm Beach Atlantic College to work around Epstein's house. Maxwell had told her that they needed irls to work at the house to answer phones and run errands. accepted the job Si an working at Epstein's house on El

indirect injuries, that is injuries sustained not as a direct result of predicate acts . . . will not allow recovery under Florida RICO."' (quoting O'Malley v. St. Thomas Univ., Inc., 599 M. 2d 999, 1000 (Fla. 3d DCA 1992))) (emphasis added). Because the Amended Complaint does not satisfy the direct-inj

ree years. Epstein has paid to erform Swedish Massages (Deep Tissue) on him and other guests. explained that approximately three year ago she met Ghislaine Maxwell and Jeffrey Epstein through a mutual friend. Epstein and Maxwell were looking for a massage therapist. stated since that time, she is notified wh

m and other guests. explained that approximately three year ago she met Ghislaine Maxwell and Jeffrey Epstein through a mutual friend. Epstein and Maxwell were looking for a massage therapist. stated since that time, she is notified when Epstein is coming to Palm Beach. stated she comes to his hous

lained that approximately three year ago she met Ghislaine Maxwell and Jeffrey Epstein through a mutual fri

'indirect injuries, that is injuries sustained not as a direct result of predicate acts . . wit! not allow recovery under Florida RICO."' (quoting O'Malley v. St. Univ., Inc., 599 So. 2d 999, 1000 (Fla. 3d DCA 1992))) (emphasis added). Because the Amended Complaint does not satisfy the direct-injury

ersity's Center for Security Studies," and David Maxwell, a "former US Special Forces officer and North Ko

evidence and witnesses' testimony to support the charges against the Ataligs. `These defendants betrayed the trust of the people of the CNMI,' said O'Malley." Marianas Variety <https://www.mvariety.cornknmi-loca1/73-local/6039-jurors-hear-closing-arguments-in-rota- mayor-s-trial> (8/24, Manabat) reports,

ersity's Center for Security Studies," and David Maxwell, a "former US Special Forces officer and North K

d evidence and witnesses' testimony to support the charges against the Ataligs. `These defendants betrayed the trust of the people of the CNMI; said O'Malley." Marianas Variety (8/24, Manabat) reports, "District Court for the NMI Chief Judge Ramona V. Manglona, for her part, told the jurors: `You heard e

ersity's Center for Security Studies," and David Maxwell, a "former US Special Forces officer and North K

evidence and witnesses' testimony to support the charges against the Ataligs. 'These defendants betrayed the trust of the people of the CNMI,' said O'Malley." Marianas Variety (8/24, Manabat) reports, "District Court for the NMI Chief Judge Ramona V. Manglona, for her part, told the jurors: 'You heard e