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

fully submitted. II. The Privilege 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 summa

s case. As one of innumerable examples, on March 8, 2010, Mr. Horowitz, representing seven victims, Jane Doe's 2-8, asked, "Q: In 2004, did you rub Jane Doe 3's vagina? A: Excuse me. I'd like to answer that question, as I would like to answer mostly every question you've asked me here today; however, upon ad

his and other information, Edwards served Maxwell for deposition in 2009. See Deposition Notice attached as Exhibit "." Maxwell was represented by Brett Jaffe of the New York firm of Cohen and Gresser, and Edwards understood that her attorney was paid for (directly or indirectly) by Epstein. She was reluct

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

Fifth Avenue, Suite 3100 New York, NY 10118 19. Ross Gow (video) 15 EFTA00792770 Acuity Representation 23 Berkeley Square London W1J 6HE 20. Brett Jaffe (live) Alston & Bird, LLP, NY 90 Park Avenue New York, NY 10016 21. Robert Hanson (live) 22. (live) do Philip Barden Devonshires Solicitors L

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

W. Es lin, Ed.D. live) 17. Anthony Figueroa (video) 18. Louis Freeh (live) SE 19. Ross Gow (video) 15 EFTA00617410 Acuit Re resentation 20. Brett Jaffe (live) Alston & Bird, LLP, NY 90 Park Avenue New York, NY 10016 21. Robert Hanson (live) 23. Brittany Henderson (video) 24. Peter Kent live 25

s case. As one of innumerable examples, on March 8, 2010, Mr. Horowitz, representing seven victims, Jane Doe's 2-8, asked, "Q: In 2004, did you rub Jane Doe 3's vagina? A: Excuse me. I'd like to answer that question, as I would like to answer mostly every question you've asked me here today; however, upon ad

is and other information, Edwards served Maxwell for deposition in 2009. See Deposition Notice attached as Exhibit "BB." Maxwell was represented by Brett Jaffe of the New York firm of Cohen and Gresser, and Edwards understood that her attorney was paid for (directly or indirectly) by Epstein. She was reluct

s case. As one of innumerable examples, on March 8, 2010, Mr. Horowitz, representing seven victims, Jane Doe's 2-8, asked, "Q: In 2004, did you rub Jane Doe 3's vagina? A: Excuse me. I'd like to answer that question, as I would like to answer mostly every question you've asked me here today; however, upon ad

is and other information, Edwards served Maxwell for deposition in 2009. See Deposition Notice attached as Exhibit "BB." Maxwell was represented by Brett Jaffe of the New York firm of Cohen and Greaser, and Edwards understood that her attorney was paid for (directly or indirectly) by Epstein. She was reluct

, 2010, Mr. Horowitz, representing seven victims, Jane Doe's 2-8, asked, "Q: In 2004, did you rub Jane Doe 3's

this and other information, Edwards served Maxwell for deposition in 2009. See Deposition Notice attached as Exhibit “BB.” Maxwell was represented by Brett Jaffe of the New York firm of Cohen and Gresser, and Edwards understood that her attorney was paid for (directly or indirectly) by Epstein. She was relucta

Second Renewed Motion for Leave to Assert Claim for Punitive Damages; Exhibit “D” — Edwards’ Notice of Filing of Transcript of Telephone Interview of Virginia Roberts in Support of Motion for Leave to Amended to Assert Punitive Damages; Exhibit “E” — Transcript of Deposition of Jeffrey Epstein dated January 25, 20

this and other information, Edwards served Maxwell for deposition in 2009. See Deposition Notice attached as Exhibit “BB.” Maxwell was represented by Brett Jaffe of the New York firm of Cohen and Gresser, and Edwards understood that her attorney was paid for (directly or indirectly) by Epstein. She was relucta