Epstein Secrets

SOUTHERN DISTRICT OF NEW YORK X Plaintiff. v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S OPPOSITION TO MESSRS. CASSELL AND EDWARDS' RENEWED MOTIONS TO APPEAR PRO HAC VICE Defendant Ghislaine Maxwell, by and through her attorneys, hereby submits the following opposition to Mess

the Court: • at 6:59 p.m., Letter Response to Motion addressed to Robert J. Sweet from Sigrid McCawley (Doc. #113). • at 7:03 p.m., Declaration of Bradley Edwards in Support of Motion to Appear Pro Hac Vice (Doc. #114). • at 7:14 p.m., Motion for Bradley Edwards to Appear Pro Hac Vice (Doc. #115) EFTA0060544

Court," as referenced in Motion for Paul Cassell to Appear (Doc. #112), because defense counsel had not received any such supplemental materials. [Menninger Decl. Ex. A]. Ms. McCawley responded that her "staff is scanning them to you now. You should have them shortly." Id. At 5:49 p.m., Plaintiff's counsel se

member telling them that you're not safe because you're talking about this? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Yes. BY MR. EDWARDS: Q. And that you had heard Jeffrey Epstein making threats to people on the telephone? MR. PAGLIUCA: Object to form and foundation. 3 EFTA00595615

tz 383 S. University Street BOLES, SCHILLER & FLEXNER, LLP Salt Lake it UT 4112 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale FL 33301 Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale. FL 33301 J. Stanley Pottinger 49 Twin L

threats to people on the telephone? MR. PAGLIUCA: Object to form and foundation. 3 EFTA00595615 THE WITNESS: Yes. He wasn't always friendly See Menninger Decl., Ex. F, 10:6-14; 43:15-44:4 As explained in in Wright & Miller, Federal Practice and Procedures, the use of a document during testimony to refresh

o Motion to Exceed Presumptive Ten Deposition Limit via ECF on the following: Sigrid S. McCawley 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

on behalf of Plaintiff by her attorneys, Bradley Edwards and Paul Cassell. Menningcr DecL, Ex. A, p. 4. Th

ached by Ghislaine Maxwell," and continuing that "Maxwell persuaded Jane Doe 143 (who was only fifteen years old) to come to Epstein's mansion ..." Menninger Decl., N. A at 26-29. No amount of "circumstantial evidence" can overcome the fact that Ms. Maxwell's statement was correct and that statements in the Jo