Epstein Secrets

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

purposely availed itself of the privilege of conducting business within the forum State, thus invoking the protec- tion and benefits of its laws.'" Pennzoil Prods. Co. F Colelli & Assocs., Inc., 149 F.3d 197, 203 (3d Cir.1998). A plaintiff can meet this burden in one of two ways: EFTA00187468 568 2

n Sex Suits. M. POST, Oct. 12, 2009 ("Florida lawyer Brad Edwards. who represents three of the 'Jane Does' who are suing Epstein, told Page Six that Phislaine] Maxwell would be questioned over her knowledge of how Epstein procured many of the girls.") (bold in original); Susan Spencer-Wendel, Judge Agrees

are suing Epstein, told Page Six that Phislaine] Maxwell would be questioned over her knowledge of how Ep

Doe Action as the basis for his argument that he too is similarly entitled to production of the Epstein interview for use in the Ponzi Scheme $ As Pennzoil and Sheehan illustrate, where (as here) a party files a New York proceeding seeking discovery of newsgathering material from a New York news organiz

concessions were negotiated away and host countries ran things themselves. Back to my father in Scotland, where he was visiting his old friends the Maxwells near Inverness, and then to the two-room suite at the Ritz in London about like the one in Paris. He drove the six hundred miles between, in a vintag

over the company. The required public disclosure of this, on top of the tripartite agreement and co-trustee lawsuit before, was blood in the water. Pennzoil launched a hostile takeover bid in December. My concern was that the trust should not be locked in a minority position. | met with Pennzoil in New Yo