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"

fendant's ... privacy interests.") (internal quotations omitted; quoting United States v. Rajaratnam, 708 F. Supp. 2d 371, 374-75 (S.D.N.Y. 2010)); Travelers Indem. Co. v. Excalibur Reins. Corp., 3:11-CV-1209 CSH, 2013 WL 4012772, at *3 (D. Conn. Aug. 5, 2013) ("The public's right to access court documents is n

vard Suite 2218 60 Fax: Counsel for Plaintiff Jane Doe #3 Jack Alan Goldberger Atterbury Goldberger & Wei

s battery." 3A Fla.Jur.2d Assault §1. An assault and battery are intentional acts. See generally Spivey'. Battaglia, 258 So.2d 815 (Fla. 1972); and Travelers Indem. Co.". PCR. Inc. 889 So.2d 779 (Fla. 2004). An "assault" is an intentional, unlawful offer of corporal injury to another by force, or exertion of

is a citizen and resident of the Commonwealth of Virginia, and is sui juris. 2. This Complaint is brough

battery." 3A FIa.Jur.2d Assault §1. An assault and battery are intentional acts. See generally, Spivey I. Battaglia 258 So.2d 815 (Fla. 1972); and Travelers Indem. Co. I. PCR, Inc. 889 So.2d 779 (Fla. 2004). An "assault" is an intentional, unlawful offer of corporal injury to another by force, or exertion of

Avenue Denver, Colorado 80203 PH 303.831.7364 HI 303.832.2628 www.hmtlaw.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

fendant's ... privacy interests.") (internal quotations omitted; quoting United States v. Rajaratnam, 708 F. Supp. 2d 371, 374-75 (S.D.N.Y. 2010)); Travelers Indem. Co. v. Excalibur Reins. Corp., 3:11-CV-1209 CSH, 2013 WL 4012772, at *3 (D. Conn. Aug. 5, 2013) ("The public's right to access court documents is n