Epstein Secrets

pe of this case, which is a real 23 issue, obviously. So is it you are restricting your claim to 24 the truth and falsity of the statements about Maxwell? 25 MS. McCAWLEY: Yes, that is the case, your Honor. The SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00794557 3 H3V0GIU1 1 stateme

If you notice the date of that 10 article, your Honor, it's March 5th, 2011. 11 The next document I provided is a press statement 12 issued by Ghislaine Maxwell on March 10th, 2011, so five days 13 later, in which she writes, care of her attorneys, "Ghislaine 14 Maxwell denies the various allegations abou

ided is a press statement 12 issued by Ghislaine Maxwell on March 10th, 2011, so five days 13 later, in which she writes, care of her attorneys, "Ghislaine 14 Maxwell denies the various allegations about her that have 15 appeared recently in the media. These allegations are all 16 entirely false."

re statement talks about 24 allegations against Ms. Maxwell have been proven 25 untrue. SOUTHERN DISTRICT

0 guess, unless you all think it's been covered, the Maxwell 11 motions. What do you think? 12 MR. PAGLIUC

s". 10 Your Honor will notice that this document is not 11 marked confidential, it was produced by Ms. Maxwell over a year 12 ago, it is marked Ghislaine Maxwell 0006, and it's a 13 communication between herself and Alan Dershowitz, someone with 14 whom she does not have a joint defense agreement, and that's 1

handling that. 5 This is essentially a hearsay exercise. We want information to 6 be excluded regarding Rebecca Boylan. Why? Because Rebecca 7 Boylan has not been deposed and is not going to be a witness in 8 the case. 9 As we understand what the defendant is planning to do, 10 she's planning

ss Complaints". Your Honor will notice that this document is not marked confidential, it was produced by Ms. Maxwell over a year ago, it is marked Ghislaine Maxwell 0006, and it's a communication between herself and Alan Dershowitz, someone with whom she does not have a joint defense agreement, and that's why she pr

20 21 22 23 24 25 H3VOGIU1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x VIRGINIA L. GIUFFRE, Plaintiff, Vv. 15 Civ. 7433 (RWS) GHISLAINE MAXWELL, Defendant. Oral Argument x New York, N.Y. March 31, 2017 LO310 a.m, Before? HON. ROBERT W. SWEET, District Judge APPEARANCES BOIES, SCHILLER

the scope of this case, which is a real issue, obviously. So is it you are restricting your claim to the truth and falsity of the statements about Maxwell? MS. McCAWLEY: Yes, that is the case, your Honor. The SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011305 10 id. 12 13 14

edia coverage. If you notice the date of that article, your Honor, it's March 5th, 2011. The next document I provided is a press statement issued by Ghislaine Maxwell on March 10th, 2011, so five days later, in which she writes, care of her attorneys, "Ghislaine Maxwell denies the various allegations about her th

alks about Virginia Giuffre's allegations against Ms. Maxwell have been proven untrue. SOUTHERN DISTRICT REPO

I guess, unless you all think it's been covered, the Maxwell motions. What do you think? MR. PAGLIUCA: Your

tness in the case. As we understand what the defendant is planning to do, she's planning to call Mr. Dershowitz. Mr. Dershowitz is going to say Ms. Boylan told him that Ms. Giuffre told him something, and so we have the classic hearsay within a hearsay situation. The problem, of course, is that Boylan

6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. GHISLAINE MAXWELL, Defendant. Before: x x 15 Civ. 7433 (RWS) Oral Argument New York, N.Y. March 31, 2017 10:10 a.m. HON. ROBERT W. SWEET, District J

the scope of this case, which is a real issue, obviously. So is it you are restricting your claim to the truth and falsity of the statements about Maxwell? MS. McCAWLEY: Yes, that is the case, your Honor. The SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00612251 1 2 3 4 5 6 7 9 10

If you notice the date of that 10 article, your Honor, it's March 5th, 2011. 11 The next document I provided is a press statement 12 issued by Ghislaine Maxwell on March 10th, 2011, so five days 13 later, in which she writes, care of her attorneys, "Ghislaine 14 Maxwell denies the various allegations abou

entire statement talks about allegations against Ms. Maxwell have been proven untrue. SOUTHERN DISTRICT REPO

I guess, unless you all think it's been covered, the Maxwell motions. What do you think? MR. PAGLIUCA: Your

s Complaints". Your Honor will notice that this document is not marked confidential, it was produced by Ms. Maxwell over a year ago, it is marked Ghislaine Maxwell 0006, and it's a communication between herself and Alan Dershowitz, someone with whom she does not have a joint defense agreement, and that's why she p

handling that. 5 This is essentially a hearsay exercise. We want information to 6 be excluded regarding Rebecca Boylan. Why? Because Rebecca 7 Boylan has not been deposed and is not going to be a witness in 8 the case. 9 As we understand what the defendant is planning to do, 10 she's planning

Epstein's victims, and information that would expose innocent individuals to "allegations of wrongdoing." The Daily Beast (07/06, Revell) added that Ghislaine Maxwell may be cooperating with the FBI to take down Epstein's elite collaborators in exchange for a reduced sentence. According to the article, Ma

ictims, and information that would expose innocent individuals to "allegations of wrongdoing." The Daily Beast (07/06, Revell) added that Ghislaine Maxwell may be cooperating with the FBI to take down Epstein's elite collaborators in exchange for a reduced sentence. According to the article, Maxwell is

rline ecosystem, including trusted vendors and contractors, could be at risk of being targeted by the Scattered Spider group. Hawaii Tribune (07/04, Boylan) and Daily Mail (07/05, Garino) also reported on the story. Connecticut 19-Year-Old Posed as Yahoo! And Google Worker in $245M Crypto Heist newsti

FFRE, Plaintiff, Vv. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. poe nen nee nee eee eee eee xX Defe

NIA L. GIUFFRE, Plaintiff, Vv. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. poe nen nee nee eee eee eee

g is relevant and admissible (Motion in Limine 19)... eee 29 20. The transcript of the tape recording of Mr. Dershowitz’s conversation with Rebecca Boylan is admissible (Motion 1n Limine 20)... ceececesessseeseeceeeeseeneeceseeseeneeeeeerseeeaees 31 C. Plaintiff's Remaining Motions In Limine Are Prematu

74) Jeffrey S. Pagliuca (pro hac vice) Ty Gee (pro hac vice) HADDON, MORGAN AND FOREMAN, P.C. 150 East 10" Avenue Denver, CO 80203 Attorneys for Ghislaine Maxwell 37 HOUSE_OVERSIGHT_011470 --- PAGE BREAK --- CERTIFICATE OF SERVICE I certify that on March 17, 2017, I electronically served this Defendant’s R

7/17 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK wn eee ee eee xX VIRGINIA L. GIUFFRE, Plaintiff, Vv. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. wen ee eee xX Defendant’s Response in Opposition to Plaintiff's Omnibus Motion in Limine Laura A. Menninger Jeffrey S. Pagliuca Ty G

FFRE, Plaintiff, Vv. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. wen ee eee xX Defendant’s Response

NIA L. GIUFFRE, Plaintiff, Vv. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. wen ee eee xX Defendant’s R

nt and admissible (Motion in Limine 19).................00. 29 20. The transcript of the tape recording of Mr. Dershowitz’s conversation with Rebecca Boylan is admissible (Motion in Limine 20)... ccccccccccceceeceeeceseeesecneesseesteeesaeenes 31 C. Plaintiff's Remaining Motions In Limine Are Premature an