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nd times, on August 27, 2003, Plaintiff Nelson Shanks provided notices to Defendants' counsel of the oral depositions of Defendants Jeffrey Epstein, Ghislaine Maxwell, Abigail Wexner and Leslie Wexner to be taken on September 9th and 10th, 2003 in the offices of Gollatz, Griffin & Ewing, P.C., in Philadelphia, Pa.
Page 2 of 7 Defendant ABIGAIL WEXNER H/W Defendant JEFFREY E. EPSTEIN INDIVIDUALLY doing business as J. EPSTEIN AND COMPANY, INC. Defendant GHISLAINE MAXWELL ATTORNEY TO BE NOTICED represented by CHRISTOPHER J. GUITON (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED J. FOX (See a
above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED Date Filed # Docket Text 10/02/2002 1 COMPLAINT against JEFFREY E. EPSTEIN, GHISLAINE MAXWELL, ABIGAIL WEXNER, LESLIE WEXNER ( Filing fee $ 150 receipt number 803892.), filed by NELSON SHANICS.(ti, ) Additional attachment(s) added on 2/13/20
hereby move this Court, pursuant to Fed. R. Civ. P. 26(c)(2), for a protective order to reschedule and relocate the depositions of Jeffrey Epstein, Ghislaine Maxwell, and Abigail and Leslie Wexner, who received notices of oral deposition to be taken in the offices of Plaintiff's counsel, Gollatz, Griffin & Ewing
ia to the U.S. Virgin Islands for Mr. Epstein and Ms. Maxwell; and New Albany, Ohio for the Wexners. Accordin
r place' or by using some means of 'injecting preci- sion and some means of substantiation into their allegations of fraud.'" Board of Trustees of Teamsters Local 868 Pension Fund. Foodtown, Inc., 296 F.3d 164, 173 n. 10 (3d Cir.2002) (internal citations omit- ted). 141 Plaintiffs allege that false state- me
n Kaloyeros, was later found guilty of fraud in a connected bid-rigging scheme. Additionally, Schwartz's federal roles include monitor oversight of GM's compliance with fixes secured by prosecutors after the ignition switch recall scandal, and as an overseer of the insider trading compliance of SAC
, 48, of Newburgh, pleaded not guilty and was released on $100,000 bond. After a special union board meeting in February 2016, Ulrich was fired from Teamsters Local 812 and removed from his position as trustee of the health plan "There's more to the story," Ulrich said. Former Teamsters VP Pleads Not Guilty To
n Kaloyeros, was later found guilty of fraud in a connected bid-rigging scheme. Additionally, Schwartz's federal roles include monitor oversight of GM's compliance with fixes secured by prosecutors after the ignition switch recall scandal, and as an overseer of the insider trading compliance of SAC
, 48, of Newburgh, pleaded not guilty and was released on $100,000 bond. After a special union board meeting in February 2016, Ulrich was fired from Teamsters Local 812 and removed from his position as trustee of the health plan "There's more to the story," Ulrich said. 2 EFTA00065023 SDNY News Clips, Febru
Entities connected to both Ghislaine Maxwell and Teamsters Local

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
Bill Clinton
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATION
Donald Trump
PERSONthe Southern District
LOCATION
Julie K. Brown
PERSON
Virginia Giuffre
PERSON
New York
LOCATIONDoug Band
PERSON
Joe Biden
PERSON
David Rodgers
PERSON
Stephen Hawking
PERSON
Kenneth Marra
PERSON
Wilbur Ross
PERSON
Bloomberg L.P.
ORGANIZATION
Alexander Acosta
PERSON
Southern District of New York
ORGANIZATION