Epstein Secrets

d acted in any way inappropriately with regard to Virginia [Giuffre], that I ever touched her, that I ever met her, t

al abuse Allegations. Rather, these records are an important part of this case, since they not only support the conclusion that Dershowitz abused Ms. Giuffre, but also indisputably establish Edwards and Cassell’s strong basis for filing the allegations on her behalf. Moreover, contrary to assertions made i

uded that “at this juncture in the proceedings” details about the sexual abuse she had suffered was unnecessary to making a determination “of whether Jane Doe 3 and Jane Doe 4 should be permitted to join [the other victims’] claim that the Government violated their rights under the CVRA. The factual details r

at question. I am aware that never before 2014, end of December, was it ever, ever alleged that I had acted in any way inappropriately with regard to Virginia [Giuffre], that I ever touched her, that I ever met her, that Ihad ever been with her. I was completely aware ofthat. There had never been any allega

body had taken the photograph. Given the surrounding circumstances, I thought perhaps Mr. Epstein had taken the photograph. So that would have shown Virginia Roberts's sexual abuse was not confined just to Florida, not confined to the New York mansion; it would have -- it would have presumably continued into London

owerful individual that Epstein forced then-minor Jane Doe #3 to have sexual relations with was former Harvard

aware that never, until the lies were put in a legal pleading at the end of December 2014, it was never alleged that I had any sexual contact with Virginia Roberts. I know that it was alleged that I was a 11:38:46 witness to Jeffrey Epstein's alleged abuse and that was false. I was never a witness to any of

4-2822 E-mail: [email protected] And Paul G. Cassell Pro Hac Vice Motion Pending S.J. Quinney College of Law at the University of Utah 383 S. University St. Salt Lake City, UT 84112 Telephone:801-585-5202 Facsimile:801-585-6833 E-Mail:[email protected] Attorneys for Plaintiffs Bradley J. Edwa

Case 1:15-cv-07433-RWS Document 422 Filed 09/06/16 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S RENEWED MOTION TO COMPEL SETTLEMENT AGREEMENT Laura A.

Case 1:15-cv-07433-RWS Document 422 Filed 09/06/16 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S RENEWED MOTION TO COMPEL SETTLEMENT AGREEMENT Laura A. Menninger

attorneys for You and/or Mr. Epstein." Menninger Decl. Ex. A. • On March 16, 2016 Defendants responded to the Request for production stating "Ms. Giuffre is in possession of a document that contains a confidentiality provision. If Defendant obtains, and produces to Ms. Giuffre, a written waiver from .

DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant.

E, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 [email protected] Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 [email protected] J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 [email protected] Is/ N

ts of New York, I BRADLEY J. EDWARDS, hereby move this Court for an Order for admission to practice Pro Hac Vice to appear as counsel for Plaintiff, VIRGINIA L. GIUFFRE, in the above-captioned action. 1 am in good standing of the bar(s) of the state(s) of Florida and there are no pending disciplinary proceedings ag

COURT SOUTHERN DISTRICT OF NEW YORK Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghis

ES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RW

0011 Facsimile: (954)456-0022 Email: [email protected] Paul G Cassell (Pro Hac Vice) S.J. Quinney College of Law at The University of Utah 383 S. University Street Salt Lake City, UT 84112-0730 Telephone (801)-585-5202 Facsimile: (801)-585-2750 Email: [email protected] Sigrid McCawley (Pro Hac Vi

Y-0023148 EFTA_00 170862 EFTA01297311 Page 2 Giuffre V. Maxwell 1:15cv7433 SOUTHERN DISTRICT OF NEW Y

0590 (917)-446-4641 Email:[email protected] Paul G Cassell [ATTORNEY TO BE NOTICED] S.J. Quinney College of Law At The University of Utah 383 S. University Street Salt Lake City, UT, USA 84112-0730 (801)-585-5202 Fax: (801)-585-2750 Email:[email protected] DEFENDANT ATTORNEY(S): Jeffrey S. Pagliu

EFTA00617181 the Southern District of Florida Giuffre 007597- 007605 District of Florida Justice D

J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale. FL 33301 Paul G. Cassell 383 S. University Street Salt Lake City. UT 84112 J. Stanley Pottinger 49 Twin Lakes Rd. South Salem m i NY 105 0 Is/ Nicole Simmons Nicole Simmons 7 EFTA0061

a minor child." David Boies Is Now Representing Jane Doe #3 (Apr. 26, 2015), http:/hhecareerist.typepad.comit

J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 Paul G. Cassell 383 S. University Street Salt Lake City UT 84112 J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 Is/ Nicole Simmons Nicole Simmons 13 EFTA00618146

Page 3 Giuffre V. Maxwell 1:15cv7433 401 East Las Olas Boulevar

0590 (917)-446-4641 Email:[email protected] Paul G Cassell [ATTORNEY TO BE NOTICED] S.J. Quinney College of Law At The University of Utah 383 S. University Street Salt Lake City, UT, USA 84112-0730 (801)-585-5202 Fax: (801)-585-2750 Email:Cassellp@law. Utah. Edu DEFENDANT ATTORNEY(S): Jeffrey S. Pagl

s were "redundant, immaterial, impertinent, or scandalous." See Doe v. United States, 08-cv-80736 (S.D.Fla.), DE 324 at 4. Ex. F. Specifically as to Jane Doe 3, Judge Marra found her allegations of being "sexually trafficked to several high-profile non-party individuals" to be "lurid" and "unnecessary" to

ICRIEGER KIM & LEWIN, LLP 500 Fifth Avenue New York. NY 10110 this Ms. Maxwell's Reply In Support of Her on the following: Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 Imran H. Ansari AIDALA, BERTUNA & KAMINS, P.C. 546 Fifth Avenue 6th Floor New York, NY 10036 Jay M. Wolman Ma

ecL, Ex. A, p. 4. The very first line describing Jane Doe #3 Circumstances is false, ft read: "In 1999, Jane

Meridith Schultz Boors, SCHILLER & FLEXNER, LLP Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FiSTOS & LEHRMAN, P.L. Paul G. Cassell 383 S. University Street J. Stanley Pottinger SIM Is/ Nicole Simmons Nicole Simmons 10 EFTA00097405