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r women, among their other duties, worked to ensure that an appointment book for twice- or thrice-daily "massages" was stocked with fresh recruits. Ghislaine Maxwell, daughter of the late Czechoslovakian-born press baron Robert Maxwell. who was for many years Epstein's live-in partner, also recruited young girls.
odeling agency. According to a complaint filed in the U.S. District Court for the Southern Di trict of Florida, an alleged victim said that Epstein, Maxwell. Brunel, Rodriguez, and "deliberately engaged in a pattern of racketeering that involved luring minor children through MC2, mostly girls under the
cording to a complaint filed in the U.S. District Court for the Southern District of Florida, an alleged victim said that Epstein • and girlfriend Ghislaine] Maxwell, Brunel. [house manager Alfredo] Rodriguez. and 'deliberately engaged in a pattern of racketeering that involved luring minor children thro
nship. unlike the confidential relationship of a doctor and patient or attorney and client, warrants no privilege beyond the terms of Rule 410. See Jaffee, 518 M. at 10. But the victims would enjoy an evidentiary benefit from the disclosure of plea negotiations to prove whether the United States violat
our women, among their other duties, worked to ensure that an appointment book for twice- or thrice-daily “massages” was stocked with fresh recruits. Ghislaine Maxwell, daughter of the late Czechoslovakian-born press baron Robert Maxwell, who was for many years Epstein’s live-in partner, also recruited young girls.
modeling agency. According to a complaint filed in the U.S. District Court for the Southern District of Florida, an alleged victim said that Epstein, Maxwell, Brunel, Rodriguez, and Marcinkova “deliberately engaged in a pattern of racketeering that involved luring minor children through MC2, mostly girls u
to a complaint filed in the U.S. District Court for the Southern District of Florida, an alleged victim said that Epstein, [assistant and girlfriend Ghislaine] Maxwell, Brunel, [house manager Alfredo] Rodriguez, and Marcinkova ‘deliberately engaged in a pattern of racketeering that involved luring minor chi
ionship, unlike the confidential relationship of a doctor and patient or attorney and client, warrants no privilege beyond the terms of Rule 410. See Jaffee, 518 U.S. at 10. But the victims would enjoy an evidentiary benefit from the disclosure of plea negotiations to prove whether the United States viola
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t the federal government does not intervene in sex-assault cases, except if we're deal- ing with a serial rapist or it crosses jurisdictional lines," Maxwell said. "It's either not a big enough case or not atrocious enough for them." Epstein, 56, served 13 months of his 18-month sentence at the Palm Beac
ionship, unlike the confidential relationship of a doctor and patent or attorney and client, warrants no privilege beyond the terms of Rtle 410. See Jaffee. 518 U.S. at 10, 116 S. Cf. at 1928. But the victims would enjoy an evidentiary benefit from the disclosure of plea negotiations to prove whether th
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nship, unlike the confidential relationship of a doctor and patient or attorney and client, warrants no privilege beyond the terms of Rule 410. See Jaffee, 518 U.S. at 10. But the victims would enjoy an evidentiary benefit from the disclosure of plea negotiations to prove whether the United States vio
mi Attn: SSA From: Miami Squad PB-2, PBCRA Contact: SA pproved By: Drafted By: :enk Case ID #: 31E-MM-108062 Title: CHANGED JEFFREY EPSTEIN; GHISLAINE N. MAXWELL WSTA - CHILD PROSTITUTION Synopsis: To request assignment of co-case agent and submit documents to case file. Previous Title: Title marked "
Page: EFTA02857863_p55 →ntacted 's mother in Phoenix to arrange a trip for to fly to Epstein's ranch in New Mexico. was under the impression the trip was for Epstein and Maxwell to get to know her better and finalize her summer plans for traveling to Thailand. Originally, was going to accompany to New Mexico; however, Ep
Page: EFTA02857863_p67 →ils: Precedence: ROUTINE Date: 03/12/2007 To: Miami From: Miami Approved By: Drafted By: ID #: 31E-MM-108062 (Pending) Title: JEFFREY EPSTEIN; GHISLAINE N. MAXWELL WSTA - CHILD PROSTITUTION Synopsis: To remove writer as co-case agent. Details: Due to writer's transfer from the Miami Division, PBCRA, to FBIHQ, e
Page: EFTA02857863_p107 →FFRE, Plaintiff, Vv. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. poe nen nee nee eee eee eee xX Defe
Page: HOUSE_OVERSIGHT_011463 →NIA L. GIUFFRE, Plaintiff, Vv. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. poe nen nee nee eee eee eee
Page: HOUSE_OVERSIGHT_011463 →cione v. Hustler Magazine, Inc., 800 F.2d 298, 303 (2d Cir. 1986)... ce eeeeeesesseeseeeseeeeeees 13 ill HOUSE_OVERSIGHT_011466 --- PAGE BREAK --- Jaffee v. Redmond, 518 U.S. 1, 116 S.Ct. 1923, 135 L.Ed.2d 337 (1996) oe ceeeescesseeeseerseeesees 22 Kadant Johnson Inc. v. D’Amico, No. CIV.A. 10-2869, 2
Page: HOUSE_OVERSIGHT_011467 →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
Page: HOUSE_OVERSIGHT_011471 →Microsoft Word - 2017.03.16 Deft Resp IO to Ptfs Omnibus Motn in Limine (MASTER).docx
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
Page: HOUSE_OVERSIGHT_014788 →FFRE, Plaintiff, Vv. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. wen ee eee xX Defendant’s Response
Page: HOUSE_OVERSIGHT_014788 →NIA L. GIUFFRE, Plaintiff, Vv. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. wen ee eee xX Defendant’s R
Page: HOUSE_OVERSIGHT_014788 →d Cir. 1986)... ccccccecceeeeees 13 iil HOUSE_OVERSIGHT_014791 --- PAGE BREAK --- Case 1:15-cv-07433-RWS Document 749 Filed 03/17/17 Page 5 of 9 Jaffee v. Redmond, 518 U.S. 1, 116 S.Ct. 1923, 135 L.Ed.2d 337 (1996) oo... cece eeeeees 22 Kadant Johnson Inc. v. D'Amico, No. CIV.A. 10-2869, 2012 WL 219
Page: HOUSE_OVERSIGHT_014792 →Entities connected to both Ghislaine Maxwell and Jaffee

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
United States
LOCATION
George W. Bush
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATION
FedEx
ORGANIZATION
Marc Rich
PERSON
Donald Trump
PERSONLeon Black
PERSON
Bradley Edwards
PERSONJeffrey Pagliuca
PERSONthe Southern District
LOCATION
Eric Trump
PERSON
Julie K. Brown
PERSONLaura Menninger
PERSON
Virginia Giuffre
PERSON
New York
LOCATION