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

n's Fund Am. Life Ins. Co., 819 F.2d 1471 (8th Cir. 1987) 7, 8 Denney v. 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. U

think they're taking a narrow uncontested principle, that her net worth doesn't come in, and are going to try to use it to exclud vidence 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

she takes the Fifth. There are other things as well. For example, Sarah Ransome testified, I witnessed with my own two eyes Sarah Kellen reporting to Ghislaine in front of me, but I can't remember specifics. They weren't talking about girls. I can't remember the specific conversation, but every single perso

uts. At page 387: I witnessed the same thing -- all the girls did -- the same thing I had to do was go and report to Sarah Kellen, 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

are going to try to use it to exclud vidence that Ms. Maxwell is making payments to the girls, that this mansio

s, oh, it's never been applied in a case like this. I would just direct your attention, as I did during the Epstein argument, to the case of FDIC v. Fidelity & Deposit Co. of Maryland. That's a Fifth Circuit case from 1995, in which a bank officer was accused of dishonest and fraudulent acts and kind of bogus loans, and

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

, oh, it's never been applied in a case like this. I would just direct your attention, as I did during the Epstein argument, to the case of FDIC v. Fidelity & Deposit Co. of Maryland. That's a Fifth Circuit case from 1995, in which a bank officer was accused of dishonest and fraudulent acts and kind of bogus loans,