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

above, such invocation has no bearing on the issues in this matter. Moreover, it is obviously cumulative and duplicative. Plaintiff also identifies Rinaldo Rizzo and Jean Luc Brunel but fails to provide any information from which Ms. Maxwell or the Court could identify the subject matter of their expected te

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

icating whether such witness will testify in person or by deposition: Plaintiff's Statement: 1. Daniel Wilson (live) 2. (video) 3. (live) 4. Rinaldo Rizzo (live) 5. Tony Figueroa (video) 6. (live) 7. (live) 8. (video) 9. (video) 10. Detective Recarey (video) 11. Alexander Hall (voice recor

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

icating whether such witness will testify in person or by deposition: Plaintiff's Statement: 1. Daniel Wilson (live) 2. (video) 3. (live) 4. Rinaldo Rizzo (live) 5. Tony Figueroa (video) 6. (live) 8. (video) 9. (video) 10. (video) 11. (voice recording) 12. Jean Luc Brunel (live) 13. Jeff

ow 9 C. Jean Luc Brunel 10 D. Jeffrey Epstein 12 E. and 14 II. FIFTH AMENDMENT BY EPSTEIN, OR NOT ADMISSIBLE IN THIS CASE AGAINST MS. MAXWELL 15 III. PLAINTIFF'S BAD FAITH DISCOVERY TACTICS SHOULD NOT BE REWARDED WITH EXTRA TIME 18 1. Plaintiff's Rule 26 Revolving Door 18 2. Plainti

, 2014 WL 4354691, at *15 (S.D.N.Y. Sept. 2, 2014) 20 ii EFTA00605114 Case 1:15-cv-07433-RWS Document 228 Filed 06/20/16 Page 4 of 29 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Combined Response ("Response") in Opposition to Plaintiff's Motion to Extend Deadline to Complete Depositions ("Motion")

SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL. Defendant. X 15-cv-07433-RWS DEFENDA

PSTEIN, OR NOT ADMISSIBLE IN THIS CASE AGAINST MS. MAXWELL 15 III. PLAINTIFF'S BAD FAITH DISCOVERY TACTIC

26 disclosures served on November 11, 2015 and two of the six were specifically mentioned in Plaintiff's Complaint. Finally, the fact that witness Rinaldo Rizzo had a deposition re-scheduled from April until June does not have any bearing on the issue presented by this motion. Mr. Rizzo was deposed on June

CONFIDENTIAL TREATMENT REQUESTED / FED. R. CRIM. P. 6(e) MATERIAL BSF RESPONSE TO GRAND JURY SUBPOENA v. Maxwell, 15 Civ. 7433 (RWS), S.D.N.Y. In Re: Grand Jury Subpoena, Sealed Order, 19 Misc. 149 (Apr. 9, 2019) PLEADINGS AND ORDERS 2016-2018 Pleadings (Rela

R-A-LAGO 0001 0607 000001 000558 000001 000009 VICTIMS_REFUSE_SILENCE 0001 0091 Deposition Transcripts (ALL) April 22, 2016 De osition of Ghislaine Maxwell May 3, 2016 Deposition of May 18, 2016 Deposition of May 20, 2016 Deposition of Sky Roberts May 24, 2016 Deposition of Lynn Trude Miller May

Transcripts (ALL) April 22, 2016 De osition of Ghislaine Maxwell May 3, 2016 Deposition of May 18, 2016

ition of Dr. Steven Olson June 1, 2016 Deposition Transcript of Juan Alessi June 3, 2016 Deposition of David Rodgers June 10 2016 De osition of Rinaldo Rizzo June 20 2016 Deposition of June 21, 2016 Deposition of Joseph Recarey June 23, 2016 Deposition of James Austrich June 24, 2016 Deposition of

CONFIDENTIAL TREATMENT REQUESTED / FED. R. CRIM. P. 6(e) MATERIAL .F ESPONSE TO GRAND JURY SUBPOENA v. Maxwell, 15 Civ. 7433 (RWS), S.D.N.Y. In Re: Grand Jury Subpoena, Sealed Order, 19 Misc. 149 (Apr. 9, 2019) PLEADINGS AND ORDERS 2016 Pleadings (Related S

014402 MAR-A-LAGO 0001 0607 W 000001 000558 000001 000009 VICTIMS_REFUSE_SILENCE 0001 0091 Transcripts (ALL) April 22, 2016 De sition of Ghislaine Maxwell May 3, 2016 Deposition of May 18, 2016 Deposition of May 20, 2016 Deposition of Sky Roberts May 24, 2016 Deposition of Lynn Trude Miller May

Transcripts (ALL) April 22, 2016 De sition of Ghislaine Maxwell May 3, 2016 Deposition of May 18, 2016

ition of Dr. Steven Olson June 1, 2016 Deposition Transcript of Juan Alessi June 3, 2016 Deposition of David Rodgers June 10, 2016 De sition of Rinaldo Rizzo June 20, 2016 Deposition of June 21, 2016 Deposition of Joseph Recarey June 23, 2016 Deposition of James Austrich June 24, 2016 Deposition of

tle 243 Riverside, Dr. New York, NY 10025 141' Ghislaine Maxwell Address Currently Unknown 142 Records Custodia

iverside, Dr. New York, NY 10025 141' Ghislaine Maxwell Address Currently Unknown 142 Records Custodia

tle 243 Riverside, Dr. New York, NY 10025 141' Ghislaine Maxwell Address Currently Unknown 142 Records

ll also confirm the leadership role played by Edwards in the prosecution of civil claims against Epstein and the propriety of Edwards' actions. 21. Rinaldo Rizzo do Robert Lewis 228 East 45th Street I 17th Floor New York, NY 10017 2-3 Expected to testify about the malicious prosecution elements of absence

ims of his sexual molestations. 145. Phone journal taken from Epstein's home and produced to the FBI by Alfredo Rodriguez. 146. Photo depicting Ghislaine Maxwell, and Prince Andrew. 147. Al flight logs for any Epstein owned or controlled aircraft. This is so overbroad that Epstein cannot possibly make a det

edo Rodriguez. 146. Photo depicting Ghislaine Maxwell, and Prince Andrew. 147. Al flight logs for any

BI by Alfredo Rodriguez. 146. Photo depicting Ghislaine Maxwell, and Prince Andrew. 147. Al flight logs

rn District of Florida 15. Records Custodian of the Federal Bureau of Investigations 16. Spencer Kuvin, Esquire 17. Theodore Leopold, Esquire 18. Rinaldo Rizzo 19. Adam Horowitz, Esquire 20. Isidro M. Garcia, Esquire 21. All of the Lawyers who Represented Victims of Jeffrey Epstein. This is so overbroad th

er Circle of Jeffrey Epstein — Part II Ghisaline Maxwell Lesley Gross Larry Visoski (Pilot) Dave Rodger

2 EFTA00098756 These are all people that may or may not cooperate during any criminal investigation. Inner Circle of Jeffrey Epstein — Part II Ghisaline Maxwell Lesley Gross Larry Visoski (Pilot) Dave Rodgers (Pilot) Jojo Fontenella Joseph "Gypsy" Alvarez (California Native American Healer) — Provides gi

FTA00098757 Victims Not Identified in the NPA People with Information Regarding Crimes Committed Outside Florida and Not Covered by the NPA "en Rinaldo Rizzo (New York) Former Employee of Glenn Dubin with knowledge of Epstein underage activity Igor Zinoview (Former Bodyguard in New York) Not loyal to E