Epstein Secrets

n with ... over 100 massages and all but three of the massages were sexual[] in nature." (Ex. C at 23:19-22). The massages took place in Epstein's Palm Beach residence and Accuser-4 was either nude or partially nude. (Ex. C at 22:20-24:6). Payment Payment "Epstein or one of his employees ... paid [Acc

RETRIAL MOTIONS RELATING TO THE S2 SUPERSEDING INDICTMENT Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C.

rd Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C

"declarant" as to the names, addresses, phone numbers or any non-handwritten information Palm Beach Police Report Statements collected by the Palm Beach Police Department from witnesses who had been inside the Epstein mansion Names of witnesses listed in the re .ort• also Plaintiff fails

X 15-cv-07433-RWS RESPONSE TO PLAINTIFF'S NOTICE OF INTENT TO OFFER STATEMENTS UNDER, IF NECESSARY, THE RESIDUAL HEARSAY RULE Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 EFTA00617178 Defendant Ghislaine Maxwell ("Ms. Maxwell") hereby

DUAL HEARSAY RULE Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 Ea

a box containing an item described as "Twin Torpedos." This box was apparently seized during the execution of a search warrant at 358 El Brillo Way, Palm Beach, Florida, on October 20, 2005. These items are inadmissible for the reasons discussed in Ms. Maxwell's Motion to Exclude Items Purportedly Seized Du

RICA, v. GHISLAINE MAXWELL, Defendant. x GHISLAINE MAXWELL'S MOTION TO PRECLUDE INTRODUCTION OF GOVERNMENT EXHIBITS 251, 288, 294, 313 AND 606 Jeffrey S. Pagliuca Laura A. Menninger HADDON MOR AN & FOREMAN P.C. Denver.", Phone: Christian R. Everdell COHEN & GRESSER LLP New York NY 10022 Phone: Bobbi C.

T EXHIBITS 251, 288, 294, 313 AND 606 Jeffrey S. Pagliuca Laura A. Menninger HADDON MOR AN & FOREMAN P.C.

er women, were any devices or sex toys used as part of the sexual activity? A. No. Q. Were you ever involved in sexual activities in Mr. Epstein's Palm Beach house that included the use of sex toys or any kind of mechanical or other device? MR. PAGLIUCA: Objection to form and foundation. A. No. Q. Were

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can yo

er women, were any devices or sex toys used as part of the sexual activity? A. No. Q. Were you ever involved in sexual activities in Mr. Epstein's Palm Beach house that included the use of sex toys or any kind of mechanical or other device? MR. PAGLIUCA: Objection to form and foundation. A. No. Q. Were

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can yo

er women, were any devices or sex toys used as part of the sexual activity? A. No. Q. Were you ever involved in sexual activities in Mr. Epstein's Palm Beach house that included the use of sex toys or any kind of mechanical or other device? MR. PAGLIUCA: Objection to form and foundation. A. No. Q. Were

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can yo