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

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 summarize Defendant's assertions regarding her relationship to each of th

on January 6, 2015, #1030-43. c. Jaffe on March 15, 2011, #1000-19.2 Gow on January 2, 2011, #1020-26. Gow and Basham on January 2, 2015, #1027- Barden #1059-83, Some emails were forwarded or carbon copied ("CC'd") later in the chain, leading to some overlap and duplication. Whether one party or

it's interesting, because you heard defense counsel here not too long ago saying that they wanted to get in police reports of an under-aged minor, Virginia Giuffre, from when she was 14, being raped by two SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011426 10 id. 12 13 14 L5 16 ne)

efense will take a differing point of view on this, but in our view, the conspiracy's next echelon is Kellen and Marcinkova. And so for example, Ms. Giuffre has made allegations about certain things. Ms. Maxwell can't remember or denies them, so of course Ms. Giuffre then looks to corroborate her allegat

in trying to preserve that nonprosecution agreement, which means, of course, attacking people who are attacking the nonprosecution agreement, such as Jane Doe 3, that is, my client, Ms. Giuffre. And that is the first factor, the nature of the relationship there. Very tightly bound. The second one is the de

to get in police reports of an under-aged minor, Virginia Giuffre, from when she was 14, being raped by two

ing offered for the truth of the matter asserted, we want to offer it to show Ms. Maxwell's state of mind when she issued her statement through Mr. Barden and Mr. Gow. So the huge problem with that, your Honor, which Ww ' ve already dealt with, is, Ms. Maxwell has no knowledge of what's in these poli

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

hey have the burden of proving that what Ms. Maxwell said was false. That's what is at issue. We have to look at Ms. Maxwell's statement issued by Barden and Gow and then go backwards from there. And the burden on the plaintiff is proving falsity of that statement. It is not the situation where -- wh

nst me by the woman identified in court papers as Jane Doe #3 are unequivocally false and deeply offensive and

wrote: I didn't do a statement. Want me lawyer to talk to your a come up with something. + I need to distance myself probably from you in some way. Barden my lawyer is going to call yours today. Who or what is Kathy?? What gossip. Helps me to know if you cab share plse. See bellow. THE TERRAMAR PROJEC

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

d, the media obtained copies of the motion. At issue is a January 2, 2015, statement prepared by Ms. Maxwell's British solicitor Philip Barden. Mr. Barden sent the statement to Ms. Maxwell for approval and, following approval, caused Mr. Gow to send (via email) the statement to six to thirty members of

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

d, the media obtained copies of the motion. At issue is a January 2, 2015, statement prepared by Ms. Maxwell's British solicitor Philip Barden. Mr. Barden sent the statement to Ms. Maxwell for approval and, following approval, caused Mr. Gow to send (via email) the statement to six to thirty members of

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

the burden of proving that what Ms. Maxwell said was false. 16 That's what is at issue. We have to look at Ms. Maxwell's 17 statement issued by Barden and Gow and then go backwards from 18 there. And the burden on the plaintiff is proving falsity of 19 that statement. It is not the situation whe

g to preserve that nonprosecution 8 agreement, which means, of course, attacking people who are 9 attacking the nonprosecution agreement, such as Jane Doe 3, 10 that is, my client, Ms. 11 And that is the first factor, the nature of the 12 relationship there. Very tightly bound. 13 The second one i

fered for the truth of 5 the matter asserted, we want to offer it to show Ms. Maxwell's 6 state of mind when she issued her statement through Mr. Barden 7 and Mr. Gow. So the huge problem with that, your Honor, which 8 we've already dealt with, is, Ms. Maxwell has no knowledge of 9 what's in the