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of underage girls." Id. In the joinder motion, also alleged she was "forced" to have sex with Harvard law professor Alan Dershowitz, "model scout" Jean Luc Brunel, and "many other powerful men, including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Pr
professor Alan Dershowitz, "model scout" Jean Luc Brunel, and "many other powerful men, including numerou
aw professor Alan Dershowitz, "model scout" Jean Luc Brunel, and "many other powerful men, including numerou
T PERJURIOUS AS A MATTER OF LAW Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim Attorneys for Ghislaine Maxwell EFTA00097378 TABLE OF CONTENTS TABLE OF CONTENTS i TABLE OF AUTHORITIES ii
conditions she has proposed. " Any incentive Ms. Maxwell might have to flee to Fiance has been greatly diminished by the recent arrest in France of Jean-Luc Brunel. who reportedly is under investigation for alleged sexual assaults by Jeffrey Epstein. See. e.g.. France Derails Modeling Agent in Jeffrey Epstein I
ished by the recent arrest in France of Jean-Luc Brunel. who reportedly is under investigation for allege
iminished by the recent arrest in France of Jean-Luc Brunel. who reportedly is under investigation for allege
New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: Bobbi C. Sternheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00093305 Cgase
conditions she has proposed. 8 Any incentive Ms. Maxwell might have to flee to France has been greatly diminished by the recent arrest in France of Jean-Luc Brunel. who reportedly is under investigation for alleged sexual assaults by Jeffrey Epstein. See. e.g.. France Details Modeling Agent in Jeffrey Epstein I
Page: EFTA00015990 →ished by the recent arrest in France of Jean-Luc Brunel. who reportedly is under investigation for allege
Page: EFTA00015990 →iminished by the recent arrest in France of Jean-Luc Brunel. who reportedly is under investigation for allege
Page: EFTA00015990 →a Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303-831-7364 Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100 Attorneys for Ghislaine Maxwell II EFTA00015991
Page: EFTA00015991 →New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00016769 --- P
Page: EFTA00016769 →conditions she has proposed. S Any incentive Ms. Maxwell might have to flee to France has been greatly diminished by the recent arrest in France of Jean-Luc Brunel, who reportedly is under investigation for alleged sexual assaults by Jeffrey Epstein. See, e.g., France Details Modeling Agent in Jeffrey Epstein I
Page: EFTA00016782 →ished by the recent arrest in France of Jean-Luc Brunel, who reportedly is under investigation for allege
Page: EFTA00016782 →iminished by the recent arrest in France of Jean-Luc Brunel, who reportedly is under investigation for allege
Page: EFTA00016782 →e: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303-831-7364 Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100 Attorneys for Ghislaine Maxwell EFTA000
Page: EFTA00019291 →conditions she has proposed. 8 Any incentive Ms. Maxwell might have to flee to France has been greatly diminished by the recent arrest in France of Jean-Luc Brunel, who reportedly is under investigation for alleged sexual assaults by Jeffrey Epstein. See, e.g., France Details Modeling Agent in Jeffrey Epstein I
Page: EFTA00019304 →ished by the recent arrest in France of Jean-Luc Brunel, who reportedly is under investigation for allege
Page: EFTA00019304 →iminished by the recent arrest in France of Jean-Luc Brunel, who reportedly is under investigation for allege
Page: EFTA00019304 →D TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Sternheim Attorneys for Ghislaine Maxwell EFTA00029100 --- PAGE BREAK --- Table of Contents Table of Contents Fable of Authorities ii Table of Exhibit
Page: EFTA00029100 →photos were found on or produced from any computers associated with Maxwell. 2 EFTA00029106 --- PAGE BREAK --- o That Maxwell and Epstein-friend Jean Luc Brunel "took sexually explicit photos of [M] regularly."2 Id. o That, as a birthday present, Maxwell gave Epstein a sexually explicit photo of taken whe
Page: EFTA00029107 →K --- o That Maxwell and Epstein-friend Jean Luc Brunel "took sexually explicit photos of [M] regularly
Page: EFTA00029107 →BREAK --- o That Maxwell and Epstein-friend Jean Luc Brunel "took sexually explicit photos of [M] regularly
Page: EFTA00029107 →Entities connected to both Jean-Luc Brunel and Bobbi C. Sternheim

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSONJeffrey Pagliuca
PERSON
Bradley Edwards
PERSON
Marc Rich
PERSONLaura Menninger
PERSON
Michael Cohen
PERSONDarren Indyke
PERSON
Donald Trump
PERSONJane Doe
PERSON
United States
LOCATION
John F. Kennedy
PERSON
Alfredo Rodriguez
PERSON
Department of Justice
ORGANIZATION
Richard Kahn
PERSONCohen & Gresser LLP
ORGANIZATION
Paul Cassell
PERSONthe Southern District
LOCATION