Epstein Secrets

Case 1:15-cv-07433-RWS Document 25 Filed 12/28/15 Page 1 of 13 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK Plaintiff, Ghislaine Maxwell, Defendant. Case No.: I5-cv-07433-RWS REPLY MEMORANDUM OF LAW IN SUPPORT OF DEFENDANT'S MOTION TO DISMISS COMPLAINT Laura A. Menninger HADDON,

INTRODUCTION ARGUMENT I. PLAINTIFF FAILED TO PLAUSIBLY PLEAD DEFAMATION A. Plaintiff Failed to Adequately Plead a Defamation Claim 1 B. Ms. Maxwell's Statement In Context Is Not Defamatory 3 II. MS. MAXWELL'S STATEMENTS ARE PROTECTED BY PRIVILEGE 6 A. Qualified Privilege May Form the Basis f

OR THE SOUTHERN DISTRICT OF NEW YORK Plaintiff, Ghislaine Maxwell, Defendant. Case No.: I5-cv-07433-RWS

ed to Adequately Plead a Defamation Claim 1 B. Ms. Maxwell's Statement In Context Is Not Defamatory 3 II.

with the Clerk of Court using the CM/ECF system which will send notification to all counsel of record including the following: Sigrid S. McCawley Boies, Schiller & Flexner, LLP East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale. FL 33301 s/ Brenda Rodriguez 11 EFTA00591589

HERN DISTRICT OF NEW YORK X L. Plaintiff. v. GHISLAINE MAXWELL. Defendant. X 15-cv-07433-RWS Objecti

d by Bradley Edwards (Doc#86). In the alternative Ms. Maxwell requests that the Court modify the Protective Or

EMAN, P.C. East 10th Avenue Denver, CO 80203 EFTA00595640 Case 1:15-cv-07433-RWS Document 88 Filed 04/08/16 Page 2 of 7 INTRODUCTION Defendant Ghislaine Maxwell, through her attorneys, objects to the Motion for Admission Pro Hac Vice filed by Bradley Edwards (Doc#86). In the alternative Ms. Maxwell requests

Ghislaine Maxwell, through her attorneys, objects to the Motion for Admission Pro Hac Vice filed by Bradley Edwards (Doc#86). In the alternative Ms. Maxwell requests that the Court modify the Protective Order, (Doc. # 62) to restrict Mr. Edwards's access to information designated "confidential" for the

for the following reasons. ARGUMENT This case has been pending since September 21, 2015. Plaintiff is represented in this case by 4 attorneys from Boies, Schiller & Flexner, LLP who have entered their appearances in this matter. On March 18, 2016, the Court entered a Protective Order restricting the use of information

Case 1:15-cv-07433-RWS Document 88 Filed 04/08/16 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X L. Plaintiff, v. GHISLAINE MAXWELL Defendant. X 15-cv-07433-RWS Objection to Motion to Appear Pro Hac Vice of Bradley James aim, ards or, Alternatively, to Modify the Prot

15-cv-07433-RWS Document 88 Filed 04/08/16 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X L. Plaintiff, v. GHISLAINE MAXWELL Defendant. X 15-cv-07433-RWS Objection to Motion to Appear Pro Hac Vice of Bradley James aim, ards or, Alternatively, to Modify the Protection O

REMAN, P.C. East 10th Avenue Denver, CO 80203 EFTA00595633 Case 1:15-cv-07433-RWS Document 88 Filed 04/08/16 Page 2 of 7 INTRODUCTION Defendant Ghislaine Maxwell, through her attorneys, objects to the Motion for Admission Pro Hac Vice filed by Bradley Edwards (Doc#86). In the alternative Ms. Maxwell requests

d by Bradley Edwards (Doc#86). In the alternative Ms. Maxwell requests that the Court modify the Protective Or

for the following reasons. ARGUMENT This case has been pending since September 21, 2015. Plaintiff is represented in this case by 4 attorneys from Boies, Schiller & Flexner, LLP who have entered their appearances in this matter. On March 18, 2016, the Court entered a Protective Order restricting the use of information

06/16 Page 3 of 15 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Reply In Support of her Motion to C

Case 1:15-cv-07433-RWS Document 191 Filed 06/06/16 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff. v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S REPLY IN SUPPORT OF MOTION TO COMPEL NON-PRIVILEGED DOCUMENTS Laura A. Menninger Jeffrey S.

ent With Her Own Attorneys 10 CERTIFICATE OF SERVICE 13 EFTA00618133 Case 1:15-cv-07433-RWS Document 191 Filed 06/06/16 Page 3 of 15 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Reply In Support of her Motion to Compel Non-Privileged Documents contained on Plaintiff's Privilege Log, stating as foll

ys 10 CERTIFICATE OF SERVICE 13 EFTA00618133 Case 1:15-cv-07433-RWS Document 191 Filed 06/06/16 Page 3 of 15 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Reply In Support of her Motion to Compel Non-Privileged Documents contained on Plaintiff's Privilege Log, stating as follows: INTRODUC

Schiller's public statements concerning its representation of Plaintiff, in which they claimed to be acting pro bono: "According to a statement by Boies, Schiller & Flexner, the firm is representing Roberts on a pro bono basis: The firm's pro bono program focuses on meaningful cases including trying to assist women and

RT SOUTHERN DISTRICT OF NEW YORK x 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Plaintiff, New York, N.Y. v. GHISLAINE MAXWELL, Defendant. Before: x 15 Civ. 7433(RWS) June 23, 2016 12:19 p.m. HON. ROBERT W. SWEET, District Judge APPEARANCES BOIES, SCHILLER &

. She wasn't SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA_R1_00024125 EFTA01737529 19 G6ndgium there when whatever happened with Ms. Maxwell and 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 took place, witnessing it as citizen Sharon Churcher. All of

22 23 24 25 Plaintiff, New York, N.Y. v. GHISLAINE MAXWELL, Defendant. Before: x 15 Civ. 7433(RWS) June

19 G6ndgium there when whatever happened with Ms. Maxwell and 4 5 6 7 8 9 10 11 12 13 14 15 16

The problem for me or the problem for them? THE COURT: The problem for the plaintiffs. MS. SCHULTZ: Thank you, your Honor. Meredith Schultz, from Boies, Schiller & Flexner, on behalf of Ms. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA_R1_00024114 EFTA01737518 8 G6ndgium 1 4 5 6 7 8 9 10 11 12