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

H3V0GIU1 1 these other things that are circulating about her that have 2 nothing to do with Ms. Maxwell. 3 Mr. Cassell referred to our expert Phillip Esplin, 4 Dr. Esplin, and saying that he agreed not to refer to 5 as a prostitute. Your Honor, that came up in the 6 context of a cross examination in

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

24 25 53 H3VOGIU1 these other things that are circulating about her that have nothing to do with Ms. Maxwell. Mr. Cassell referred to our expert Phillip Esplin, Dr. Esplin, and saying that he agreed not to refer to Virginia Roberts as a prostitute. Your Honor, that came up in the context of a cross examina

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

VOGIU1 53 1 these other things that are circulating about her that have 2 nothing to do with Ms. Maxwell. 3 Mr. Cassell referred to our expert Phillip Esplin, 4 Dr. Esplin, and saying that he agreed not to refer to 5 s a prostitute. Your Honor, that came up in the 6 context of a cross examination in

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL Defendant. X 15-cv-07433-RWS DEFENDANT'S REPLY IN SUPPORT OF MOTION IN LIMINE TO EXCLUDE IN TOTO CERTAIN DEPOSITIONS DESIGNATED BY PLAIN

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL Defendant. X 15-cv-07433-RWS DEFENDANT'S REPLY IN SUPPORT OF MOTION IN LIMINE TO EXCLUDE IN TOTO CERTAIN DEPOSITIONS DESIGNATED BY PLAINTIFF FOR

Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 EFTA00595612 Defendant Ghislaine Maxwell ("Ms. Maxwell") files her Reply in Support of the Motion in Limine to Exclude In Toto certain depositions designated by Plaintiff for use at trial a

203 EFTA00595612 Defendant Ghislaine Maxwell ("Ms. Maxwell") files her Reply in Support of the Motion in Li

essions, the Motion in Limine to exclude the use of the designated portions of these depositions in toto must be granted. B. As a Retained Expert, Phillip Esplin Cannot Be Deemed Unavailable Plaintiff's argument concerning Phillip Esplin fails to acknowledge or even address the cases cited that require that

CONFIDENTIAL TREATMENT REQUESTED / FED. R. CRIM. P. 6(e) MATERIAL BISSI F ESPONSE TO GRAND JURY SUBPOENA v. Maxwell, 15 Civ. 7433 (RWS), S.D.N.Y. In Re: Grand Jury Subpoena, Sealed Order, 19 Misc. 149 (Apr. 9, 2019) PLEADINGS AND ORDERS 2016-2018 Pleadings (Rela

MAR-A-LAGO 0001 0607 000001 000558 RG(UK) 000001 000009 VICTIMS_REFUSE_SILENCE 0001 0091 Transcripts (ALL) April 22, 2016 De osition of Ghislaine Maxwell May 3, 2016 Deposition of May 18, 2016 Deposition of May 20, 2016 - Deposition of May 24, 2016 Deposition of May 26, 2016 Deposition of Dr.

Transcripts (ALL) April 22, 2016 De osition of Ghislaine Maxwell May 3, 2016 Deposition of May 18, 2016

ember 22, 2016 Deposition of with Errata Sheet November 29, 2016 Deposition of November 30, 2016 Deposition of December 1, 2016 Deposition of Phillip Esplin December 2, 2016 Deposition of Gregory Taylor Index to BSF ShareFile Materials loaded on April 18-19 and April 23, 2019 EFTA00081371 FOIA CONFI

CONFIDENTIAL TREATMENT REQUESTED / FED. R. CRIM. P. 6(e) MATERIAL BSF RESPONSE TO GRAND JURY SUBPOENA v. Maxwell, 15 Civ. 7433 (RWS), S.D.N.Y. In Re: Grand Jury Subpoena, Sealed Order, 19 Misc. 149 (Apr. 9, 2019) PLEADINGS AND ORDERS 2016-2018 Pleadings (Rela

R-A-LAGO 0001 0607 000001 000558 000001 000009 VICTIMS_REFUSE_SILENCE 0001 0091 Deposition Transcripts (ALL) April 22, 2016 De osition of Ghislaine Maxwell May 3, 2016 Deposition of May 18, 2016 Deposition of May 20, 2016 Deposition of Sky Roberts May 24, 2016 Deposition of Lynn Trude Miller May

Transcripts (ALL) April 22, 2016 De osition of Ghislaine Maxwell May 3, 2016 Deposition of May 18, 2016

on with Errata Sheet November 29, 2016 Deposition of Peter Kent November 30, 2016 Deposition of Frederick Miller December 1, 2016 Deposition of Phillip Esplin December 2, 2016 Deposition of Gregory Taylor Index to BSF ShareFile Materials loaded on April 18-19 and April 23, 2019 EFTA00090987 FOIA CONFI

CONFIDENTIAL TREATMENT REQUESTED / FED. R. CRIM. P. 6(e) MATERIAL .F ESPONSE TO GRAND JURY SUBPOENA v. Maxwell, 15 Civ. 7433 (RWS), S.D.N.Y. In Re: Grand Jury Subpoena, Sealed Order, 19 Misc. 149 (Apr. 9, 2019) PLEADINGS AND ORDERS 2016 Pleadings (Related S

014402 MAR-A-LAGO 0001 0607 W 000001 000558 000001 000009 VICTIMS_REFUSE_SILENCE 0001 0091 Transcripts (ALL) April 22, 2016 De sition of Ghislaine Maxwell May 3, 2016 Deposition of May 18, 2016 Deposition of May 20, 2016 Deposition of Sky Roberts May 24, 2016 Deposition of Lynn Trude Miller May

Transcripts (ALL) April 22, 2016 De sition of Ghislaine Maxwell May 3, 2016 Deposition of May 18, 2016

on with Errata Sheet November 29, 2016 Deposition of Peter Kent November 30, 2016 Deposition of Frederick Miller December 1, 2016 Deposition of Phillip Esplin December 2, 2016 Deposition of Gregory Taylor Index to BSF ShareFile Materials loaded on April 18-19, 2019 EFTA00090984 FOIA CONFIDENTIAL TREAT