Epstein Secrets

United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. I PLAINTIFF REPLY IN SUPPORT OF MOTION TO PRESENT TESTIMONY FROM JEFFREY EPSTEIN FOR PURPOSES OF OBTAINING AN ADVERSE INFERENCE INS

Sent Wednesday, January 21, 2015 4.47 PM To: G Maxwell Subject FW Guardian This will now end but I th

mail.com, Sent Thursday, January 15, 2015 5:27 PM To: Gmax do you want shwIly to come out and say she was the girlfriend , during the time . be GM 01081. Or this email, in which Epstein urges Defendant to send a dismissive press statement: 2 As the Court will recall from earlier proceedings in

" See Plaintiffs' Response to Defendant's Motion for Summary Judgment at 7. explained that when Defendant called, she would just say: "Hi. This is Ghislaine. Jeffrey was wondering if you had anybody that could come over." Id. And there is significant related evidence collected in the summary judgment mo

March 9th, 2001, you, the Defendant in this case, Ms. Maxwell, Emmie M, and ] flew on your private jet from

Jenkens & Gilchrist, 362 F. Supp. 2d 407 (S.D.N.Y. 2004) 6 F.D.I.C. v. Fidelity & Deposit Co. of Maryland, 45 F.3d 969 (5th Cir. 1995) 6 In re WorldCom, Inc. Securities Litigation, 2005 WL 375315 (S.D.N.Y. Feb. 17, 2005) 17 LiButti v. United States, 107 F.3d 110 (2d Cir. 1997) passim Rules Fe

hey're taking a narrow 6 uncontested principle, that her net worth doesn't come in, and 7 are going to try to use it to exclude evidence that Ms. Maxwell 8 is making payments to the girls, that this mansion is a very 9 THE COURT: Well, okay. I don't think so. 10 MR. CASSELL: Let me just make sure

our Honor. Mr. Edwards -- again, 12 who is a party in this deposition and not a lawyer -- chimes in 13 to the special master and Mr. Dershowitz: "Q. Ghislaine 14 Maxwell was never the target of the investigation, was she?" 15 Confirming and arguing that Dershowitz is wrong about this 16 joint defense

uts. 21 At page 387: I witnessed the same thing -- all the girls 22 did -- the same thing I had to do was go and report to 23 Leslie Groff, and Ghislaine Maxwell. Ghislaine was the 24 main lady. So again, we have an allegation by our client that 25 Ms. Maxwell was a part of a larger conspiracy. That's one

e going to try to use it to exclude evidence that Ms. Maxwell 8 is making payments to the girls, that this ma

he kind of questions that have 16 been disapproved in the Second Circuit. And that's Brink's 17 Inc. v. City of New York, which is in the papers; WorldCom 18 Security Litigation, also in the papers; and LiButti itself. 19 These are not technical objections. It serves no legitimate 20 evidentiary p

hink they're taking a narrow uncontested principle, that her net worth doesn't come in, and are going to try to use it to exclude evidence that Ms. Maxwell is making payments to the girls, that this mansion is a very - THE COURT: Well, okay. I don't think so. MR. CASSELL: Let me just make sure that I

our Honor. Mr. Edwards -- again, 12 who is a party in this deposition and not a lawyer -- chimes in 13 to the special master and Mr. Dershowitz: "Q. Ghislaine 14 Maxwell was never the target of the investigation, was she?" 15 Confirming and arguing that Dershowitz is wrong about this 16 joint defense

and thereabouts. At page 387: I witnessed the same thing -- all the girls did -- the same thing I had to do was go and report to Leslie Groff, and Ghislaine Maxwell. Ghislaine was the main lady. So again, we have an allegation by our client that Ms. Maxwell was a part of a larger conspiracy. That's one of SOUT

e going to try to use it to exclude evidence that Ms. Maxwell is making payments to the girls, that this mansi

he kind of questions that have 16 been disapproved in the Second Circuit. And that's Brink's 17 Inc. v. City of New York, which is in the papers; WorldCom 18 Security Litigation, also in the papers; and LiButti itself. 19 These are not technical objections. It serves no legitimate 20 evidentiary p

e the other four were filed by women who have gone public with their allegations of sexual abuse. Ho claims she was violently groped by Epstein and Ghislaine Maxwell in 1996, is one of the women. Her sister a who alleges that Epstein made her give him a topless massage when she was underage, also filed a separa

she was violently groped by Epstein and Ghislaine Maxwell in 1996, is one of the women. Her sister a who

Ho claims she was violently groped by Epstein and Ghislaine Maxwell in 1996, is one of the women. Her sister

ent, compared with 34 in all of 2018. Punishment versus mercy Among those to benefit from the law was Bernard Ebbers, the former chief executive of WorldCom, a telecom giant once valued at more than $150 billion. Ebbers was convicted in 2005 of securities fraud for falsifying the company's financial res

y judge c airman smisse yju 9e New York Judge Maxwell Wiley dismissed state charges against former Trum

nly federal prison were executions take place. Former prison guard, Kevin Beaver described death row as "a very choreographed area." Bernie Ebbers, WorldCom Chief Jailed for Fraud, Will Leave Prison Early The New York Times https://www.nytimes.com/2019/12/18/business/bernard-ebbers-prison-release.html

an-dismissed-by-judge-2019-12-18/ New York Judge Maxwell Wiley dismissed state charges against former Trum

nly federal prison were executions take place. Former prison guard, Kevin Beaver described death row as "a very choreographed area." Bernie Ebbers, WorldCom Chief Jailed for Fraud, Will Leave Prison Early The New York Times https://www.nytimes.com/2019/12/18/business/bernard-ebbers-prison-release.html