Epstein Secrets

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

xhibits 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., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 Da

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

xhibits 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., Suite 1200 Ft. Lauderdale, FL 33301 David Boies Boies

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

Cawley Sigrid McCawley, Esq. EFTA00622199 Dated: March 2, 2017. Respectfully Submitted, BOLES, SCHILLER & FLEXNER LLP By: Is/ Sigrid McCawley Sigrid S. McCawley(Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boles Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 David Boles Boles