Epstein Secrets

pe of this case, which is a real 23 issue, obviously. So is it you are restricting your claim to 24 the truth and falsity of the statements about Maxwell? 25 MS. McCAWLEY: Yes, that is the case, your Honor. The SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00794557 3 H3V0GIU1 1 stateme

If you notice the date of that 10 article, your Honor, it's March 5th, 2011. 11 The next document I provided is a press statement 12 issued by Ghislaine Maxwell on March 10th, 2011, so five days 13 later, in which she writes, care of her attorneys, "Ghislaine 14 Maxwell denies the various allegations abou

ided is a press statement 12 issued by Ghislaine Maxwell on March 10th, 2011, so five days 13 later, in which she writes, care of her attorneys, "Ghislaine 14 Maxwell denies the various allegations about her that have 15 appeared recently in the media. These allegations are all 16 entirely false."

re statement talks about 24 allegations against Ms. Maxwell have been proven 25 untrue. SOUTHERN DISTRICT

0 guess, unless you all think it's been covered, the Maxwell 11 motions. What do you think? 12 MR. PAGLIUC

s". 10 Your Honor will notice that this document is not 11 marked confidential, it was produced by Ms. Maxwell over a year 12 ago, it is marked Ghislaine Maxwell 0006, and it's a 13 communication between herself and Alan Dershowitz, someone with 14 whom she does not have a joint defense agreement, and that's 1

Oral Argument New York, N.Y. 9 March 31, 2017 10:10 a.m. 10 Before: 11 HON. ROBERT W. SWEET, 12 District Judge 13 APPEARANCES 14 BOIES, SCHILLER & FLEXNER LLP 15 Attorneys for Plaintiff BY: SIGRID S. McCAWLEY, ESQ. 16 MEREDITH L. SCHULTZ, ESQ. 17 S.J. QUINNEY COLLEGE OF LAW AT THE UNIVERSITY OF UTAH

enies." "Ms. Roberts claims are obvious lies and should be treated as such and not publicized as news, as they are defamatory." 4 EFTA00792759 "Ghislaine Maxwell's original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavory nature, which have appeared

l was living in New York. Plaintiff is a United States Citizen. Plaintiff is seeking damages in excess of $75,000.00. Defendant's Statement: Ms. Maxwell agrees with the Plaintiff's statement, above. iv. A brief summary by each party of the claims and defenses that party has asserted which remain to

t the repetition of such old defamatory claims." GM 00068. Plaintiff's Complaint also seeks damages

York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant JOINT PRETRIAL STATEMENT Pu

in excess of $75,000.00. Defendant's Statement: Ms. Maxwell agrees with the Plaintiff's statement, above. iv

unds of authenticity, and two stars indicating exhibits to which no party objects on any ground. 17 EFTA00792772 Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid S. McCawley(Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Sui

ch he denies." "Ms. claims are obvious lies and should be treated as such and not publicized as news, as they are defamatory." 4 EFTA00617399 "Ghislaine Maxwell's original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavory nature, which have appeared

l was living in New York. Plaintiff is a United States Citizen. Plaintiff is seeking damages in excess of $75,000.00. Defendant's Statement: Ms. Maxwell agrees with the Plaintiff's statement, above. iv. A brief summary by each party of the claims and defenses that party has asserted which remain to

t the repetition of such old defamatory claims." GM 00068. Plaintiff's Complaint also seeks damages

York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant JOINT PRETRIAL STATEMENT Pu

in excess of $75,000.00. Defendant's Statement: Ms. Maxwell agrees with the Plaintiff's statement, above. iv

unds of authenticity, and two stars indicating exhibits to which no party objects on any ground. 17 EFTA00617412 Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid S. McCawley(Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Sui

MAXWELL JEFFREY EPSTEIN, PRINCE ANDREW, 3/22/20 EFTA00075107 Casgastetal14331atitilmetbdOnttit7187.82412CF 057g9/28gEFEeigef 6208161 Socialite Ghislaine Maxwell 'groped a 16-year-old girl during a naked massage,' victims' lawyer says El dailvmail.co.ukThews/article-8163681/Socialite-Ghislaine-Maxwell-qroped-1

.com Re: Reconsideration of the Court's July 23 Ruling Giuffie v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its Protective Order and punish its violation. Ms. Maxwell's two deposition transcripts were designated

rated for Jeffrey Epstein's personal sexual satisfaction. So to the degree that um there was a main facilitator that started the whole thing, it was Ghislaine. 3 A purported transcript of the press conference is contained on the intemet at https://www.rev.comiblog,/transcripts/announcement-transcript-of-c

v. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its

ining the Maxwell materials from Boies Schiller, the Maxwell Protective Order explicitly provides that (1) di

engh d0910 EXHIBIT D EFTA00075093 02/26/2016 14:Qe*A41Sam.24)1721.313dcAPIe CitaliarilieffiltrI8Q4RO,Faii9657329 Puce 202 laib 0001/0026 BOLES, SCHILLER & FLEXNER LLP Sie,'w Vert( ■ WasbinntotitDC Florida • New i California New Jersc • 401 East Las Olas Blvd., Suite 1200 Fort Lauderdale, Florida 33301 Telepho

TO: Laura Menninger, Esq. Haddon, Morgan and Foreman, P.C. Fax No. Telephone No. FROM: Sigrid S. McCawley, Esq. DATE: February 26, 2016 RE: r. Maxwell, Case no. 15-cv-07433-RWS Total Number of Pages: 26 (including this cover sheet) MESSAGE: Attached please find a copy of my email transmission

1:15-cv-07433-LAP Document 1078-4 Filed 07/29/20 Page 3 of 1010019/0026 United States District Court Southern District Of New York Plaintiff, v. Ghislaine Maxwell, Defendant. 15-cv-07433-RWS AGREED PROTECTIVE ORDER Upon a showing of good cause in support of the entry of a protective order to protect the di

McCawley, Esq. DATE: February 26, 2016 RE: r. Maxwell, Case no. 15-cv-07433-RWS Total Number of Pages

t Southern District Of New York Plaintiff, v. Ghislaine Maxwell, Defendant. 15-cv-07433-RWS AGREED PRO

d 07/29/20 Page 1 of 10 EXHIBIT D EFTA00094794 02/26/2016 14:COSM.:15-cv-07433-LAP Document 1078-4 Filed 07/29/20 Page 2 of Dam 000liao26 BOIES, SCHILLER & FLEXNER LLP Ngsv York I Washinntore.DCli Florida i California &New Jerse FACSIMILE COVER SHEET TO: Laura Menninger, Esq. Haddon, Morgan and Foreman, P.C. F

1 of 37 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X VIRGINIA L. GUIFFRE, Plaintiff, 15 Civ. 7433 (RWS) - against - OPINION GHISLAINE MAXWELL, Defendant. X APpEARANCE S: Counsel for Plaintiffs BOEIS, SCHILLER & FLEXNER LLP 401 East Las Olas Boulevard, Suite 1200 Fort Lauderd

07433-RWS Document 135 Filed 05/02/16 Page 2 of 37 Sweet, D.J. Plaintiff Virginia Giuffre ("Giuffre" or "Plaintiff") has moved to compel Defendant Ghislaine Maxwell ("Maxwell" or "Defendant") to produce documents withheld on the grounds of privilege.- !lased on the conclusions set forth below, the motion is gr

35 Filed 05/02/16 Page 2 of 37 Sweet, D.J. Plaintiff Virginia Giuffre ("Giuffre" or "Plaintiff") has moved to compel Defendant Ghislaine Maxwell ("Maxwell" or "Defendant") to produce documents withheld on the grounds of privilege.- !lased on the conclusions set forth below, the motion is granted in p

d NY law." Privilege Log at 1. Defendant argues "Ms. Maxwell's communications with Mr. Barden should be const

L. GUIFFRE, Plaintiff, 15 Civ. 7433 (RWS) - against - OPINION GHISLAINE MAXWELL, Defendant. X APpEARANCE S: Counsel for Plaintiffs BOEIS, SCHILLER & FLEXNER LLP 401 East Las Olas Boulevard, Suite 1200 Fort Lauderdale, FL 33301 By: Sigrid S. McCawley, Esq. Meredith L. Schultz, Esq. Counsel for Defendants

vision? We're going to 5 present to the jury it's Maxwell who got the benefit of the 6 immunity provision

onor -- the first line, second sentence. "The 21 allegations made by," and then it says Victoria which 22 is inaccurate by the drafter, "against Ghislaine Maxwell are 23 untrue." And then it follows. But that is the backdrop to 24 this. And she's responding to things about herself, not about 25 anybody el

E COURT: So problems enough I've got. 3 MR. EDWARDS: I understand. I understand, your Honor. 4 So at a time when Jeffrey Epstein is investigated, Ghislaine 5 Maxwell is flying on his plane, she's vacationing with him. We 6 have flight logs, we have photographs that were taken during 7 that time. 8

vocacy 22 statements by Kliman, such as calling Ms. Maxwell a 23 perpetrator, someone he's never met before

) Oral Argument New York, N.Y. March 31, 2017 12:08 p.m. 10 Before: 11 HON. ROBERT W. SWEET, 12 District Judge 13 APPEARANCES 14 BOIES, SCHILLER & FLEXNER LLP 15 Attorneys for Plaintiff BY: SIGRID S. McCAWLEY, ESQ. 16 MEREDITH L. SCHULTZ, ESQ. 17 S.J. QUINNEY COLLEGE OF LAW AT THE UNIVERSITY OF UTAH

Laura Menninger, Esq. Haddon, Morgan and Foreman, P.C. Fax No. Telephone No. FROM: Sigrid S. McCawley, Esq. DATE: February 26, 2016 RE: .r . Maxwell, Case no. 15-cv-07433-RWS Total Number of Pages: 26 (including this cover sheet) MESSAGE: Attached please find a copy of my email transmission

:15-cv-07433-LAP Document 1078-4 Filed 07/29/20 Page 3 of 1010019/0026 United States District Court Southern District Of New York Plaintiff, v. Ghislaine Maxwell, Defendant. 15-cv-07433-RWS AGREED PROTECTIVE ORDER Upon a showing of good cause in support of the entry of a protective order to protect the di

t Southern District Of New York Plaintiff, v. Ghislaine Maxwell, Defendant. 15-cv-07433-RWS AGREED PRO

07/29/20 Page 1 of 10 EXHIBIT D EFTA00084356 02/26/2016 14:Cgqckg.:15-cv-07433-LAP Document 1078-4 Filed 07/29/20 Page 2 of ladi000liao26 BOIES, SCHILLER & FLEXNER LLP S6. York Nal shire r California a New Jersey 4 FACSIMILE COVER SHEET TO: Laura Menninger, Esq. Haddon, Morgan and Foreman, P.C. Fax No. Telep

-RWS Document 89 Filed 04/10/16 Page 1 of 10 United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF, CONSOLIDATED REPLY IN OPPOSITION TO DEFENDANT'S MOTIONS TO DISOALIFY PROFESSOR CASSELL AND MR. EDWARDS FROM REPRESENTING

intiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF, CONSOLIDATED REPLY IN O

York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF, CONSOLIDATED RE

a motions). Dated: April 10, 2016 8 EFTA00600143 Case 1:15-cv-07433-RWS Document 89 Filed 04/10/16 Page 9 of 10 Respectfully Submitted, BOLES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Boles, Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301

United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF'S NOTICE OF SERVICE OF RULE 45 SUBPOENA FOR DOCUMENTS UPON DAVID RODGERS (A/K/A DAVE RODGERS) PLEASE TAKE NOTICE THAT, purs

ying, testing, or sampling of the material: All flight logs for any and all aircrafts, including charter flights, relating to Jeffrey Epstein and/or Ghislaine Maxwell for the period covering July 1, 1991 through the present Of not duplicative of previous production). Place. Boles, Schiller & Flexner LLP

intiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF'S NOTICE OF SERVICE OF RU

of Service of Subpoena upon David Rodgers (a/k/a Dave Rodgers). A copy of the Subpoena is attached to this Notice. Dated: February 14, 2017 ROTES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawlev Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice) David Boies Bradley J. Edwards (Pro Hac Vice) loor FARME