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

Frechtman v. Gutterman, 979 N.Y.S.2d 58 (1st Dep't 2014) 14 Front, Inc. v. Khalil, 24 N.Y.3d 713, 720 (2015) 13 Fuji Photo Film U.S.A., Inc. v. McNulty, 669 F.Supp.2d 405 (S.D.N.Y. 2009) 8 Gertz v. Robert Welch, Inc., 418 U.S. 323, 325 (1974) 17 Hawkins v. City of New York, No. 99 Civ. 11704 (RWS

w enforcement. EFTA00188663 Case 9:08-cv-80736-KAM Document 310-1 Entered on FLSD Docket 02/06/2015 Page 3 of 28 7. 1 also knew what Epstein and Maxwell had been doing the years that I was with them. In addition to constantly finding underage girls to satisfy their personal sexual desires, Epstein an

ork). Jane Doe #3 was forced to have sexual relations with this Prince when she was a minor in three separate geographical locations: in London (at Ghislaine Maxwell's apartment), in New York, and on Epstein's private island in the U.S. Virgin Islands (in an orgy with numerous other under-aged girls). Epstein inst

that I had been sexually abused by Prince Andrew, Ghislaine Maxwell, Jean Luc Brunel, Alan Dershowitz, and o

ights that are related to the prosecution of the accused and sentencing of the guilty. These rights are not civil, but criminal in nature. See In re McNulty, 597 F.3d 344. 352 n.8 (6th Cir. 2010) ("The CVRA was not enacted to short circuit civil litigation to those with valid civil remedies available.")

mployees and underlings to repeatedly find and bring minor girls to him. Epstein worked in concert as part of the enterprise with others, including Ghislane Maxwell and Jean Luc Brunel, to obtain minor girls not only for his own sexual gratification, but also for the sexual gratification of others. The FBI deter

f the enterprise with others, including Ghislane Maxwell and Jean Luc Brunel, to obtain minor girls not on

as part of the enterprise with others, including Ghislane Maxwell and Jean Luc Brunel, to obtain minor girl

cy to suppress and eliminate competition by allocating packaged-ice customers in southeastern Michigan and the Detroit, Michigan, metropolitan area. McNulty had been an employee of Arctic Glacier, and was told of the conspiracy. Id. at 346-47. When he refined to participate in the conspiracy, he was fir