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inister pattern — it is also worth noting that each of the other four individuals Jane Doe No. 3 identified by name in her motion (Jeffrey Epstein, Ghislaine Maxwell, Jean Luc Brunel, and Prince Andrew) have also all been afforded opportunities to explain themselves — and all four have declined to take them. Eps
After extensive discussion and coordinating a convenient time and place, as well as ultimately agreeing to a confidentiality agreement prepared by Maxwell's attorney, at the eleventh hour Maxwell's attorney informed the undersigned that Maxwell's mother was very ill and that consequently Maxwell was le
entified by name in her motion (Jeffrey Epstein, Ghislaine Maxwell, Jean Luc Brunel, and Prince Andrew) have
e declined to allow a mere "reputational" interest to justify mandatory intervention. For example, Calloway" Westinghouse Eke. Cop., 115 F.R.D. 73 (M.D. Ga. 1987), denied a motion to intervene where the alleged interest was a doctor's "own reputation and academic credibility." Id. at 74. The court denied inte
inister pattern — it is also worth noting that each of the other four individuals Jane Doe No. 3 identified by name in her motion (Jeffrey Epstein. Ghislaine Maxwell, Jean Luc Brunel, and Prince Andrew) have also all been afforded opportunities to explain themselves — and all four have declined to take them. Eps
ked questions about his sexual abuse of young girls. including Jane Doe No. I. Jane Doe No. 2, and Jane Doe No. 3. See generally Exhibit 16 at 1-7. Maxwell. In 2009, undersigned counsel (Brad Edwards) served Ghislaine Maxwell with a subpoena for a deposition in a civil case against Jeffrey Epstein. Afte
entified by name in her motion (Jeffrey Epstein. Ghislaine Maxwell, Jean Luc Brunel, and Prince Andrew) have
declined to allow a mere "reputational" interest to justify mandatory intervention. For example, Calloway'. Westinghouse Elea Corp., 115 F.R.D. 73 (M.D. Ga. 1987). denied a motion to intervene where the alleged interest was a doctor's "own reputation and academic credibility." Id. at 74. The court denied inte
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rties in describing what is claimed to be the law to Court. For example, the Response quotes Calloway v. Westinghouse Elec. Corp., 115 F.R.D. 73, 74 (M.D. Ga. 1987) for the proposition that “a witness’ interest in his reputation alone . . . does not constitute the required ‘interest relating to the property or t
Page: HOUSE_OVERSIGHT_010739 →ctional meeting with former President Clinton, providing an elaborate description about how Mr. Clinton and his secret service detail somehow allowed Ghislaine Maxwell, then a novice helicopter pilot, to fly all of them to Jeffrey’s Epstein’s private island on Epstein’s black helicopter, as well as details a
Page: HOUSE_OVERSIGHT_010744 →eting with former President Clinton, providing an elaborate description about how Mr. Clinton and his secret service detail somehow allowed Ghislaine Maxwell, then a novice helicopter pilot, to fly all of them to Jeffrey’s Epstein’s private island on Epstein’s black helicopter, as well as details about the
Page: HOUSE_OVERSIGHT_010744 →ws, the ex-President did not take the bait. “‘I’d have been about 17 at the time,’ [Jane Doe #3] says. ‘I flew to the Caribbean with Jeffrey and then Ghislaine Maxwell went to pick up Bill [Clinton] in a huge black helicopter that Jeffrey had bought her. She’d always wanted to fly and Jeffrey paid for her to take le
Page: HOUSE_OVERSIGHT_010744 →Entities connected to both Ghislaine Maxwell and M.D. Ga. 1987

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
United States
LOCATION
Bill Clinton
PERSON
Alan Dershowitz
PERSON
FedEx
ORGANIZATION
Marc Rich
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Virginia Giuffre
PERSON
New York
LOCATIONMaria Farmer
PERSONJane Doe
PERSON
Joe Biden
PERSON
Vicky Ward
PERSON
David Rodgers
PERSON
Palm Beach
LOCATION
Jean-Luc Brunel
PERSON
Alfredo Rodriguez
PERSON
U.S. Virgin Islands
LOCATION