Epstein Secrets

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

mmunications 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 regarding her relationship to each of these individuals. Defendant hired

for her to see Andrew three times—at Jeffrey Epstein's homes in London and New York and on his private Caribbean island, Little Saint James—where, Virginia said, she'd been "sexually exploited by Epstein's adult male peers, including royalty." Would Ghislaine please comment on this assertion by MS MAX

Subject: Re: Vanity Fair Good to go. Sent from my BlackBerry" wireless device > wrote: From: GMAX < Date: Thu, 09 Jun 2011 11:19:51 -0400 To: Brian Basham< ; Ross Gow< Subject: Re: Vanity Fair Dear Brian and Ross Bellow in caps are my proposed answers. I have no intention of talking to Ed. My plan h

ax.com> Sent: Monday, July 4, 2011 1:21 PM To: [email protected] Subject: Fw: Confidential Attachments: Police reports.pdf; ATT00065.htm; Virginia Robert Exhibits.pdf; ATT00068.htm Original Message From: Brian Basham To: Gmax Sent: Mon Jul 04 09:18:29 2011 Subject: FW: Confidential G. I'

om Subject: Fw: Confidential Attachments: Police reports.pdf; ATT00065.htm; Virginia Robert Exhibits.pdf; ATT00068.htm Original Message From: Brian Basham To: Gmax Sent: Mon Jul 04 09:18:29 2011 Subject: FW: Confidential G. I've read these and the VF article. This could all rebound badly. The report

for her to see Andrew three times—at Jeffrey Epstein's homes in London and New York and on his private Caribbean island, Little Saint James—where, Virginia said, she'd been "sexually exploited by Epstein's adult male peers, including royalty." Would Ghislaine please comment on this assertion by MS MAX

PS..PLSE COMMENT Forwarded Message From: Ross Gow Date: Tue, 7 Jun 2011 13:49:02 -0400 To: G G < maxl ellmax.com <mailto: maxi ellmax.com» Cc: Brian Basham Subject: Vanity Fair Dear Ghislaine Klein's questions follow, below. If we are to respond, I would advise we stick to written responses rather th

for her to see Andrew three times—at Jeffrey Epstein's homes in London and New York and on his private Caribbean island, Little Saint James—where, Virginia said, she'd been "sexually exploited by Epstein's adult male peers, including royalty." Would Ghislaine please comment on this assertion by MS MAX

Title: FW: Vanity Fair MY PROPOSED ANS IN CAPS..PLSE COMMENT Forwarded Message From: Ross Gow Date: Tue, 7 Jun 2011 13:49:02 -0400 To:GG< Cc: Brian Basham Subject: Vanity Fair Dear Ghislaine Klein's questions follow, below. If we are to respond, I would advise we stick to written responses rather th