Epstein Secrets

7433-RWS Document 189 Filed 06/06/16 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X INNIErt INIMINME, Plaintiff, v. GHISLATNE MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S RESPONSE IN OPPOSITION TO MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT Laura A. Menninger Jeffr

er Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. EFTA00097395 Case 1:15-cv-07433-RWS Document 189 Filed 06/06/16 Page 2 of 11 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Response in Opposition to Plaintiff's Motion to Exceed Presumptive Ten Deposition Limit, and states as follows: INTRODUC

9 Filed 06/06/16 Page 4 of 11 Plaintiff makes a bizarre argument that somehow this testimony can be used to create an adverse inference against Ms. Maxwell,2 despite the fact that Ms. Maxwell did not invoke the Fifth Amendment and she testified fully and answered every question posed to her with the only

cument 189 Filed 06/06/16 Page 2 of 11 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Response in Op

06/16 Page 2 of 11 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Response in Opposition to Plaintiff

ion would result in more than ten depositions being taken ...."); accord Universal City Studios v. Reimerdes,104 F.Supp.2d 334, 342 (S.D.N.Y.2000); Landry v. St. James Parish Sch. Rd., No. Civ. A 99-1438, 2000 WL 1741886, at •2 (E.D.La. Nov. 22, 2000). The purpose of Rule 30(a)(2)(A) is to "enable cou

onsolidated Summary Account Beginning Net Ending Net Change Start on Number Market Value Market Value In Value Page Investment Account(s) OHISLAINE MAXWELL 7.338.834.28 7.243.029 53 (95.804.75) 2 OHISLAINE MAXWELL 0.00 60.174.17 60.174 17 28 Total Value $7,338,834.28 $7,303,203.70 (535.630.5

J.P.Morgan J.P. Morgan Securities Inc. GHISI.AINE MAXWELL ACCT. 270 Park Avenue, New York, NY 10017 For the Period 1/1/09 to 1/31/09 Margin Account .I.P. Morgan Prhate Bank Team Online access www.Morg

Total Value $7,338,834.28 $7,303,203.70 (535.630.58) 000000 0000 00 0000 000 00000000) 0101,” 010'10877 O90 ;-‘7 ^0:70/ mnxt71. (,g 70.'90'30 i AINE MAXWELL Page 1 of 42 SB1062192-F1 4102 EFTA01665974 THIS PAGE INTENTIONALLY LEFT BLANK SB1062192-F1 4103 EFTA01665975 J.PMorgan JPMorgan Chase Ba

.520.51 Market Value with Accruals $7,243,029.53 $7,243,029.53 Account Page 2 of 26 SB1062192-F1 Page 3 of 42 4105 EFTA01665977 J.PMorgan GHISLAINE MAXWELL ACCT. For the Period 2/1/09 to 2/28/09 Account Summary CONTINUED Tax Summary Current Period Value Year-lo-Date Value Curren! Perio

F1 Page 3 of 42 4105 EFTA01665977 J.PMorgan GHISLAINE MAXWELL ACCT. For the Period 2/1/09 to 2/28/09 Account

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Judge Denies Bail Request. The CBS Evening NewsVI (7/14, story 12, 1:30, O'Donnell, 4.31M) reported, "Today, a federal judge in New York ruled that Ghislaine Maxwell has both the money and the motive to flee the country, and denied her request to be freed on bail. It means the alleged accomplice of accused sex t

bars since her July 2nd arrest. US District Judge Alison Nathan determined the 58-year-old British socialite should not be released on bail, saying Maxwell is a substantial EFTA00150068 actual risk of flight. Prosecutors say Maxwell has links to more than a dozen bank accounts around the world worth

14 for abuse by' convicted sex offender Jeffrey Epstein in the 1990s. The prosecutor read one of the alleged victim's statement in court. `Without Ghislaine, Jeffrey could have not done what he did. She was a predator and a monster.' A second victim, Annie Farmer, chose to speak, publicly identifying her

"The hearing was unusual in that it was virtual: Ms. Maxwell, who is being held in a federal detention center

onavirus, according to an email blast to employees of the state Department of Justice." Fox News (7/14, Phillips, 27.59M) notes on its website that Landry said in a statement, "Out of an overabundance of caution with the vice president coming to our state, I was tested for cornavirus [sic]. ... Though

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