Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL Defendant. X 15-cv-07433-RWS RESPONSE TO PLAINTIFF'S NOTICE OF INTENT TO OFFER STATEMENTS UNDER, IF NECESSARY, THE RESIDUAL HEARSAY RULE

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL Defendant. X 15-cv-07433-RWS RESPONSE TO PLAINTIFF'S NOTICE OF INTENT TO OFFER STATEMENTS UNDER, IF NECESSARY, THE RESIDUAL HEARSAY RULE Laura

Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 EFTA00617178 Defendant Ghislaine Maxwell ("Ms. Maxwell") hereby files her Response to Plaintiff's Notice of Intent to Offer Statements Under, If Necessary, the Residual Hearsay Rule and sta

203 EFTA00617178 Defendant Ghislaine Maxwell ("Ms. Maxwell") hereby files her Response to Plaintiff's Notic

navailable Deposition of Alfredo Statements regarding Alfredo Rodriguez is See Motion to Exclude Depositions In Toto and Motion in Limine re: Diane Flores 4 EFTA00617182 Rodriguez and handwriting on exhibits. Ms. Maxwell's involvement in massages given to girls and young adults, as partic

hey're taking a narrow 6 uncontested principle, that her net worth doesn't come in, and 7 are going to try to use it to exclude evidence that Ms. Maxwell 8 is making payments to the girls, that this mansion is a very 9 THE COURT: Well, okay. I don't think so. 10 MR. CASSELL: Let me just make sure

our Honor. Mr. Edwards -- again, 12 who is a party in this deposition and not a lawyer -- chimes in 13 to the special master and Mr. Dershowitz: "Q. Ghislaine 14 Maxwell was never the target of the investigation, was she?" 15 Confirming and arguing that Dershowitz is wrong about this 16 joint defense

uts. 21 At page 387: I witnessed the same thing -- all the girls 22 did -- the same thing I had to do was go and report to 23 Leslie Groff, and Ghislaine Maxwell. Ghislaine was the 24 main lady. So again, we have an allegation by our client that 25 Ms. Maxwell was a part of a larger conspiracy. That's one

e going to try to use it to exclude evidence that Ms. Maxwell 8 is making payments to the girls, that this ma

we argued it a couple weeks ago in the 16 context of another motion -- oh, I'm sorry, because, your 17 Honor, you requested that with respect to Diane Flores. So we 18 didn't reargue it today, it is fully briefed for you. 19 THE COURT: Okay. In other words, I've got everything 20 on that. 21 MS. Mc

think they're taking a narrow uncontested principle, that her net worth doesn't come in, and are going to try to use it to exclud vidence that Ms. Maxwell is making payments to the girls, that this mansion is a very -- THE COURT: Well, okay. I don't think so. MR. CASSELL: Let me just make sure that I

she takes the Fifth. There are other things as well. For example, Sarah Ransome testified, I witnessed with my own two eyes Sarah Kellen reporting to Ghislaine in front of me, but I can't remember specifics. They weren't talking about girls. I can't remember the specific conversation, but every single perso

uts. At page 387: I witnessed the same thing -- all the girls did -- the same thing I had to do was go and report to Sarah Kellen, Leslie Groff, and Ghislaine Maxwell. Ghislaine was the main lady. So again, we have an allegation by our client that Ms. Maxwell was a part of a larger conspiracy. That's one of SOUT

are going to try to use it to exclud vidence that Ms. Maxwell is making payments to the girls, that this mansio

I forget, we argued it a couple weeks ago in the context of another motion -- oh, I'm sorry, because, your Honor, you requested that with respect to Diane Flores. So we didn't reargue it today, it is fully briefed for you. THE COURT: Okay. In other words, I've got everything on that. MS. McCAWLEY: You do, yo

hink they're taking a narrow uncontested principle, that her net worth doesn't come in, and are going to try to use it to exclude evidence that Ms. Maxwell is making payments to the girls, that this mansion is a very - THE COURT: Well, okay. I don't think so. MR. CASSELL: Let me just make sure that I

our Honor. Mr. Edwards -- again, 12 who is a party in this deposition and not a lawyer -- chimes in 13 to the special master and Mr. Dershowitz: "Q. Ghislaine 14 Maxwell was never the target of the investigation, was she?" 15 Confirming and arguing that Dershowitz is wrong about this 16 joint defense

and thereabouts. At page 387: I witnessed the same thing -- all the girls did -- the same thing I had to do was go and report to Leslie Groff, and Ghislaine Maxwell. Ghislaine was the main lady. So again, we have an allegation by our client that Ms. Maxwell was a part of a larger conspiracy. That's one of SOUT

e going to try to use it to exclude evidence that Ms. Maxwell is making payments to the girls, that this mansi

forget, we argued it a couple weeks ago in the context of another motion -- oh, I'm sorry, because, your Honor, you requested that with respect to Diane Flores. So we didn't reargue it today, it is fully briefed for you. THE COURT: Okay. In other words, I've got everything on that. MS. McCAWLEY: You do,