Epstein Secrets

/15 Page 1 of 29 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X PLAINTIFF, V. GHISLAINE MAXWELL, DEFENDANT. X 15-cv-07433-RWS GHISLAINE MAXWELL'S MEMORANDUM OF LAW IN SUPPORT OF MOTION TO DISMISS COMPLAINT Laura A. Menninger, Esq. HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Ave

r CO 80203 Tel: Dated: November 30, 2015 EFTA00595583 Case 1:15-cv-07433-RWS Document 15 Filed 12/01/15 Page 2 of 29 Table of Contents I. MS. MAXWELL'S STATEMENTS ARE PRIVILEGED 9 A. The Self-Defense Privilege Protects Ms. Maxwell's Statements 9 B. The Pre-Litigation Privilege Protects Ms. Maxw

attributed statement responds directly to allegations and claims made by Plaintiff. Compl. 1 31. Likewise to the extent the claimed statement that "Ghislaine Maxwell's original response to the lies and defamatory claims remains the same" (Compl. 1 32) refers to an earlier statement describing Plaintiff's "factual

led 12/01/15 Page 2 of 29 Table of Contents I. MS. MAXWELL'S STATEMENTS ARE PRIVILEGED 9 A. The Self-Defen

eaders." Menninger Decl. Ex. C at 4-5. On April 7, 2015, U.S. District Court Judge Marra denied Plaintiff's Joinder Motion, ordered the portions of the Joinder Motion pertaining to non-parties Although the Complaint does not explicitly mention the 2011 Statement, it appears Plaintiff believes it to be the "additi

EGATIONS A. Epstein’s Sex Trafficking Enterprise 30. Plaintiff became a victim of sex trafficking and repeated sexual abuse after being recruited by Ghislaine Maxwell and Jeffrey Epstein when Plaintiff was under the age of eighteen. 31. Between 2000 and 2002, Epstein sexually abused Roberts at numerous locations i

use he feared a reopening of a federal criminal investigation of him. 49. Dershowitz made his statements pursuant to his conspiracy with Epstein and Maxwell maliciously as part of an effort to conceal sex trafficking crimes committed around the world by Epstein and other powerful persons. 50. | Dershowit

nd repeated sexual abuse after being recruited by Ghislaine Maxwell and Jeffrey Epstein when Plaintiff was un

erts] fabricated a story of abuse at the hands of Ms. Maxwell in exchange for hundreds of thousands of dollars

nationally televised news interviews, wrongfully claimed that Edwards and Cassell had engaged in unethical behavior warranting disbarment for filing the Joinder Motion that described Dershowitz’s involvement with Epstein and Roberts. Edwards, who is a prominent attorney for sexually abused women and children, and Ca

IONS A. Epstein's Sex Trafficking Enterprise 30. Plaintiff became a victim of sex trafficking and repeated sexual abuse after being recruited by Ghislaine Maxwell and Jeffrey Epstein when Plaintiff was under the age of eighteen. 31. Between 2000 and 2002, Epstein sexually abused Plaintiff at numerous locatio

e he feared a reopening of a federal criminal investigation of him. 53. Defendant made his statements pursuant to his conspiracy with Epstein and Maxwell maliciously as part of an effort to conceal sex trafficking crimes committed around the world by Epstein and other powerful persons. 54. Defendant

d repeated sexual abuse after being recruited by Ghislaine Maxwell and Jeffrey Epstein when Plaintiff was un

ationally televised news interviews, wrongfully claimed that Edwards and Cassell had engaged in unethical behavior warranting disbarment for filing the Joinder Motion that described Defendant's involvement with Epstein and Plaintiff. Edwards, who is a prominent lawyer for sexually abused women and children, and Ca