Epstein Secrets

ime the story is re told [sic] it changes with new salacious details about public figures and world leaders and now it is alleged by Ms [sic] that Alan Derschowitz [sic] is involved in having sexual relations with her, which he denies. Ms claims are obvious lies and should be treated as such and not publicis

f the media obtained copies of the motion, printed the "lurid" details in tabloid news publications, and sought comment from Ms. Maxwell, Professor Dershowitz and others. On January 2, 2015, UK lawyers for Ms. Maxwell sent representatives of British media organizations an email containing "a quotable stat

blications, and sought comment from Ms. Maxwell, Professor Dershowitz and others. On January 2, 2015, UK lawyers for M

"forced" to have sex with Harvard law professor Alan Dershowitz, "model scout" Jean Luc Brunel, and "m

HE SUPERSEDING INDICTMENT BECAUSE THE ALLEGED MISSTATEMENTS ARE NOT PERJURIOUS AS A MATTER OF LAW Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim Attorneys for Ghislaine Maxwell EFTA0009737

nd facts of the case is irreplaceable. Defendant notes that Professor Cassell and Mr. Edwards have been involved with defamation litigation against Alan Dershowitz in Florida, Edwards and Cassell v. Dershowitz, No. 15-000072 (171h Cir. Court Fla.). The parties to that lawsuit have jointly settled the claims, a

otes that Professor Cassell and Mr. Edwards have been involved with defamation litigation against Alan Dershowitz in Florida, Edwards and Cassell v. Dershowitz, No. 15-000072 (171h Cir. Court Fla.). The parties to that lawsuit have jointly settled the claims, and the dismissal of the case should be entered

been involved with defamation litigation against Alan Dershowitz in Florida, Edwards and Cassell v. Der

identified below via transmission of Notices of Electronic Filing generated by CM/ECF. Laura A. Menninger, Esq. Jeffrey S. Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: Imenningerehmflaw.com Email: jpagliuca@hmflaw.

elated to communications with or interaction with Alan Dershowitz from 1999 to present. DOCUMENT REOUE

ence of you or Jeffrey Epstein or between 1999 and 2005. DOCUMENT REOUEST NO. 32 All documents related to communications with or interaction with Alan Dershowitz from 1999 to present. DOCUMENT REOUEST NO. 33 All travel records between 1999 and the present reflecting your presence in: (a) Palm Beach, Florid

d to communications with or interaction with Alan Dershowitz from 1999 to present. DOCUMENT REOUEST NO. 33

REQUEST FOR PRODUCTION OF DOCUMENTS To DEFENDANT OHISLAINE MAXWELL via Email to the following counsel of record. Laura A. Menninger, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10m Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: [email protected] /s/ Sigrid S. McCawley S

ivilege with any of the other named Defendants. DOCUMENT REQUEST NO. 23 (Directed to All Defendants) All documents relating to communications with Alan Dershowitz from 1997- present. DOCUMENT REQUEST NO. 24 (Directed to All Defendants) All documents relating to communications with a female by the first name e

ll documents relating to communications with Alan Dershowitz from 1997- present. DOCUMENT REQUEST NO. 24 (Dir

s) All documents relating to communications with Alan Dershowitz from 1997- present. DOCUMENT REQUEST

T FOR PRODUCTION OF DOCUMENTS To DEFENDANTS via Email to the following counsel of record. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Counsel for Ghislaine Maxwell Michael Miller Justin Y.K Chu Michael A. Keough STEPTOE & JOHN

LAINE MAXWELL, SHARON CHURCHER, JEFFREY EPSTEIN, PlaintiffiAppellee, Defendant-Appellant, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNOVICH MEDIA Intervenors. ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK, 15-CV-

the nature of this case. 9 I think it's more like listing witnesses. So I would say that 10 the plaintiff should supply all residences. 11 The Dershowitz deposition will be produced under the 12 confidentiality provision. As I read what I've been given, 13 it's to be held in confidence and it will

dents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNOVICH M

GRID STONE McCAWLEY 16 -and- FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 17 BY: BRAD EDWARDS -and- 18 PAUL G. CASSELL 19 HADDON, MORGAN & FOREMAN Attorneys for Defendant 20 BY: LAURA A. MENNINGER JEFF PAGLUICA 21 22 23 24 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00076

n the defamation action established that stories, sold to tabloids for large sums of money, were in fact false. Those accused by Ms. =, Professor Alan Dershowitz, for example, denounced her as a "serial liar." Regardless, Ms. is not one of the three accusers identified in Counts One through Four of the Supe

t false. Those accused by Ms. =, Professor Alan Dershowitz, for example, denounced her as a "serial liar."

n fact false. Those accused by Ms. =, Professor Alan Dershowitz, for example, denounced her as a "ser

MOTION FOR A SEVERANCE OF AND SEPARATE TRIAL ON COUNTS FIVE AND SIX OF THE SUPERSEDING INDICTMENT Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303-831-7364 Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New Y

ents made by in 2015 were "obvious lies." Those wild, now known to be false, claims included her assertion that she had been sexually trafficked to Alan Dershowitz among other famous celebrities and politicians, and her age at the time of the claimed trafficking. The counts, collectively, are thus illogically

ion that she had been sexually trafficked to Alan Dershowitz among other famous celebrities and politicians,

ssertion that she had been sexually trafficked to Alan Dershowitz among other famous celebrities and po

MOTION FOR A SEVERANCE OF AND SEPARATE TRIAL ON COUNTS FIVE AND SIX OF THE SUPERSEDING INDICTMENT Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Phone: Christian R. Everdell COHEN & DRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Phone: Attorneys for Ghislaine Maxwel

ents made by in 2015 were "obvious lies." Those wild, now known to be false, claims included her assertion that she had been sexually trafficked to Alan Dershowitz among other famous celebrities and politicians, and her age at the time of the claimed trafficking. The counts, collectively, are thus illogically

ion that she had been sexually trafficked to Alan Dershowitz among other famous celebrities and politicians,

ssertion that she had been sexually trafficked to Alan Dershowitz among other famous celebrities and po

MOTION FOR A SEVERANCE OF AND SEPARATE TRIAL ON COUNTS FIVE AND SIX OF THE SUPERSEDING INDICTMENT Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Phone: Christian R. Everdell COHEN & DRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Phone: Attorneys for Ghislaine Maxwel