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"

engh d0910 EXHIBIT D EFTA00075093 02/26/2016 14:Qe*A41Sam.24)1721.313dcAPIe CitaliarilieffiltrI8Q4RO,Faii9657329 Puce 202 laib 0001/0026 BOLES, SCHILLER & FLEXNER LLP Sie,'w Vert( ■ WasbinntotitDC Florida • New i California New Jersc • 401 East Las Olas Blvd., Suite 1200 Fort Lauderdale, Florida 33301 Telepho

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

L. GUIFFRE, Plaintiff, 15 Civ. 7433 (RWS) - against - OPINION GHISLAINE MAXWELL, Defendant. X APpEARANCE S: Counsel for Plaintiffs BOEIS, SCHILLER & FLEXNER LLP 401 East Las Olas Boulevard, Suite 1200 Fort Lauderdale, FL 33301 By: Sigrid S. McCawley, Esq. Meredith L. Schultz, Esq. Counsel for Defendants

ly published: The basis for Ms. defamation claim is a January 2, 2016 press statement issued by Defendant to the international press as follows: "Jane Doe 3 is Victoria Roberts — so not a new individual. The allegations made by against Ghislaine Maxwell are untrue. The original allegations are not new a

unds of authenticity, and two stars indicating exhibits to which no party objects on any ground. 17 EFTA00792772 Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid S. McCawley(Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Sui

ly published: The basis for Ms. defamation claim is a January 2, 2016 press statement issued by Defendant to the international press as follows: "Jane Doe 3 is — so not a new individual. The allegations made by against Ghislaine Maxwell are untrue. The original allegations are not new and have been ful

unds of authenticity, and two stars indicating exhibits to which no party objects on any ground. 17 EFTA00617412 Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid S. McCawley(Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boies Schiller & Flexner LLP 401 E. Las Olas Blvd., Sui

you issue a press release 22 that doesn't say, "I deny being a co-conspirator," that doesn't 23 talk about that document at all other than to say Jane Doe 3 is 24 to then say we get to introduce a bunch of 25 evidence because we said she was a co-conspirator against her SOUTHERN DISTRICT REPORTERS, P

) Oral Argument New York, N.Y. March 31, 2017 12:08 p.m. 10 Before: 11 HON. ROBERT W. SWEET, 12 District Judge 13 APPEARANCES 14 BOIES, SCHILLER & FLEXNER LLP 15 Attorneys for Plaintiff BY: SIGRID S. McCAWLEY, ESQ. 16 MEREDITH L. SCHULTZ, ESQ. 17 S.J. QUINNEY COLLEGE OF LAW AT THE UNIVERSITY OF UTAH

that there are no courses taken between 22 1999 and the 2000 school year, and no courses taken during the 23 2000 to 2001 school years. 24 Ms. Giuffer's attempt to work and resume school at 25 another school as as a tenth grader in the 2001 to 2002 school SOUTHERN DISTRICT REPORTERS, P.C. (212)

Oral Argument New York, N.Y. 9 March 31, 2017 10:10 a.m. 10 Before: 11 HON. ROBERT W. SWEET, 12 District Judge 13 APPEARANCES 14 BOIES, SCHILLER & FLEXNER LLP 15 Attorneys for Plaintiff BY: SIGRID S. McCAWLEY, ESQ. 16 MEREDITH L. SCHULTZ, ESQ. 17 S.J. QUINNEY COLLEGE OF LAW AT THE UNIVERSITY OF UTAH