Epstein Secrets

Avenue Denver, Colorado 80203 PH 303.831.7364 HI 303.832.2628 www.hmllaw.com [email protected] Re: Reconsideration of the Court's July 23 Ruling Giuffie v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its Protect

baby: Virginia Roberts March 22.2020 I 3:24pm Virginia Roberts Giuffre wham Farrington Former teen "sex slave" when t

18/20 EFTA00075105 Cas63sE 941143 VI/0Rn @Want rtit7100V2 CFM2ft 057233/2 G g gatjef tv 013161 Epstein, Maxwell wanted me to have surrogate baby: Virginia Roberts March 22.2020 I 3:24pm Virginia Roberts Giuffre wham Farrington Former teen "sex slave" when they asked her, at g , pear mew sur MUM

it7100V2 CFM2ft 057233/2 G g gatjef tv 013161 Epstein, Maxwell wanted me to have surrogate baby: Virginia Roberts March 22.2020 I 3:24pm Virginia Roberts Giuffre wham Farrington Former teen "sex slave" when they asked her, at g , pear mew sur MUM says she finally fled Jeffrey Epstein and Ghislaine Maxwe

k for Epstein can be found in excerpts -- unsealed by a federal court last year -- of two 2016 depositions related to a defamation lawsuit filed by Virginia Giuffre. one of Epstein's alleged victims, who has accused Maxwell of recruiting her into Epstein's alleged child trafficking scheme, an accusation Maxwell

baby: Virginia Roberts March 22.2020 I 3:24pm Virginia Roberts Giuffre wham Farrington Former teen "sex slave"

on J. Nathan July 21, 2020 Page 7 Respectfully Submitted, Jeffrey S. Pagliuca cc: U.S. Attorney's Office for the Southern District of New York Mark Cohen Christian Everdell Cohen & Gresser LLP Laura A. Menninger Haddon, Morgan & Foreman, P.C. EFTA00075071 Cagesle120o140ZaUX.PertDo&Aflt."1016ZO.

Case 1:15-cv-07433-RWS Document 135 Filed 05/02/16 Page 1 of 37 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X VIRGINIA L. GUIFFRE, Plaintiff, 15 Civ. 7433 (RWS) - against - OPINION GHISLAINE MAXWELL, Defendant. X APpEARANCE S: Counsel for Plaintiffs BOEIS,

C #: DATE FILED: ) (,) 1 EFTA R1 00011977 EFTA01734187 Case 1:15-cv-07433-RWS Document 135 Filed 05/02/16 Page 2 of 37 Sweet, D.J. Plaintiff Virginia Giuffre ("Giuffre" or "Plaintiff") has moved to compel Defendant Ghislaine Maxwell ("Maxwell" or "Defendant") to produce documents withheld on the grounds

) (,) 1 EFTA R1 00011977 EFTA01734187 Case 1:15-cv-07433-RWS Document 135 Filed 05/02/16 Page 2 of 37 Sweet, D.J. Plaintiff Virginia Giuffre ("Giuffre" or "Plaintiff") has moved to compel Defendant Ghislaine Maxwell ("Maxwell" or "Defendant") to produce documents withheld on the grounds of privil

ilege Claims at Issue Defendant has withheld 99 pages of emails with communications involving various combinations of Brett Jaffe, Esq. ("Jaffe"), Mark Cohen, Esq. ("Cohen"), Philip Barden ("Barden"), Ross Gow ("Gown), Brian Basham ("Basham"), and The facts that follow summarize Defendant's assertions

Prince Andrew has "stepped down" as a senior royal. So what? What does that even mean? He has never faced any consequences of any kind, even though Virginia Guiffre Roberts has made consistent and credible claims that Epstein sex trafficked her to Andrew when she was just 17. EFTA00075252 CasECIa6Z1,2071a3Qortamettcl

faced any consequences of any kind, even though Virginia Guiffre Roberts has made consistent and credible

Maxwell 'has never shown any remorse [andj tormented her survivors... She has associates across the globe, some of great means.' Maxwell's attorney Mark Cohen tried to argue his client was not a flight risk, claiming she has community ties and is 'part of a very large and close family'. He said: 'Our clie

Beach mansion and dressed 'prior to sex sessions with Mr Epstein. S Maxwell herself wore black vinyl during sex sessions with Mr Epstein. 4. me Virginia was paid between US $200 and $ 5000 US sex, depending on whether it involved travel and other 5, Virginia was required to have sex with friends of

ne Maxwell Forwarded message From: GMAX Date: Fri, Mar 4, 2011 at 8:28 AM Subject: FW: Ghislaine Maxwell To: J lep Forwarded Message From: Mark Cohen c;: > Date: Fri, 4 Mar 2011 11:14:35 -0500 To: NY Max ci Subject: FW: Ghislaine Maxwell FYI, following up on my email of this morning. Again, I h

ein's Palm Beach house. 13. Ms Maxwell piloted President Bill Clinton in a helicopter to a dinner on Little St James where two brunettes Ms Maxwell, Virginia and Mr Epstein were at the table. 14. Mr Epstein bought Ms Maxwell the helicopter, homes in New York and London and a Mercedes.

GMAX <[email protected]> Date; Fri, Mar 4.2011 at8:28 AM Subject: FW: Ghislaine Maxwell To: J Jep <jeevacation(@gmail.com> Forwarded Message From: Mark Cohen Date: Fri, 4 Mar 2011 11:14:35 -0500 To: NY Max <gmax [email protected]> Subject: FW: Ghislaine Maxwell FYI, following up on my email of this morning, Ag