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.. . it defines the basic elements of a fair trial largely through the several provisions of the Sixth Amendment."' Cap/in & Drysdale, Chartered v. UnitedStates, 491 U.S. 617, 633 (1989) (citations omitted). 'The right of an accused in a criminal trial to due process is, in essence, the right to a fair oppor
tation omitted). "It has been clear for a generation that 'Fourth Amendment rights are personal rights ... [that] may not be vicariously asserted.'" United States v. Haqq, 278 F.3d 44, 47 (2d Cir. 2002) (quoting Rakers v. Illinois, 439 U.S. 128, 133-34 (1978)). Accordingly, a defendant's Fourth Amendment right
nt may violate the Fifth Amendment (or another right). In certain circumstances, a private entity may be deemed to be acting as a government agent. See United States v. Stein, 541 F.3d 130, 146 (2d Cir. 2008) ("Actions of a private entity are attributable to the State if there is a sufficiently close nexus betwe
endant also "`participat[ed] in the sexual abuse"' of others. Id. A few days later, the press reported a statement by a spokesman for the defendant, Ross Gow. Among other things, 45 =filed a corrected motion on January 2, 2015. See Doe, No. 08 Civ. 80736, Dkt. No.280. The court later struck the original
tation omitted). "It has been clear for a generation that `Fourth Amendment rights are personal rights ... [that] may not be vicariously asserted."' United States v. Haqq, 278 F.3d 44, 47 (2d Cir. 2002) (quoting Rakas v. Illinois, 439 U.S. 128, 133-34 (1978)). Accordingly, a defendant's Fourth Amendment rights
nt may violate the Fifth Amendment (or another right). In certain circumstances, a private entity may be deemed to be acting as a government agent. See United States v. Stein, 541 F.3d 130, 146 (2d Cir. 2008) ("Actions of a private entity are attributable to the State if there is a sufficiently close nexus betwe
fendant also "`participat[ed] in the sexual abuse" of others. Id. A few days later, the press reported a statement by a spokesman for the defendant, Ross Gow. Among other things, 45 Giuffre filed a corrected motion on January 2, 2015. See Doe, No. 08 Civ. 80736, Dkt. No. 280. The court later struck the o
tation omitted). "It has been clear for a generation that `Fourth Amendment rights are personal rights ... [that] may not be vicariously asserted."' United States v. Haqq, 278 F.3d 44, 47 (2d Cir. 2002) (quoting Rakas v. Illinois, 439 U.S. 128, 133-34 (1978)). Accordingly, a defendant's Fourth Amendment rights
nt may violate the Fifth Amendment (or another right). In certain circumstances, a private entity may be deemed to be acting as a government agent. See United States v. Stein, 541 F.3d 130, 146 (2d Cir. 2008) ("Actions of a private entity are attributable to the State if there is a sufficiently close nexus betwe
fendant also "`participat[ed] in the sexual abuse" of others. Id. A few days later, the press reported a statement by a spokesman for the defendant, Ross Gow. Among other things, 45 Giuffre filed a corrected motion on January 2, 2015. See Doe, No. 08 Civ. 80736, Dkt. No. 280. The court later struck the o
tation omitted). "It has been clear for a generation that `Fourth Amendment rights are personal rights ... [that] may not be vicariously asserted."' United States v. Haqq, 278 F.3d 44, 47 (2d Cir. 2002) (quoting Rakas v. Illinois, 439 U.S. 128, 133-34 (1978)). Accordingly, a defendant's Fourth Amendment rights
nt may violate the Fifth Amendment (or another right). In certain circumstances, a private entity may be deemed to be acting as a government agent. See United States v. Stein, 541 F.3d 130, 146 (2d Cir. 2008) ("Actions of a private entity are attributable to the State if there is a sufficiently close nexus betwe
to ain (Mailgjuffre alleged that "participat[ed] in the sexual A few days later, the press reported a statement by a spokesman for the defendant, Ross Gow. Among other things, Gow stated that Giuffre's claims were "untrue" and "obvious lies." (15 Civ. 7433 (LAP), Dkt. No. 1 at 6). 45 Giuffre filed a c
tation omitted). "It has been clear for a generation that `Fourth Amendment rights are personal rights ... [that] may not be vicariously asserted."' United States v. Haqq, 278 F.3d 44, 47 (2d Cir. 2002) (quoting Rakas v. Illinois, 439 U.S. 128, 133-34 (1978)). Accordingly, a defendant's Fourth Amendment rights
nt may violate the Fifth Amendment (or another right). In certain circumstances, a private entity may be deemed to be acting as a government agent. See United States v. Stein, 541 F.3d 130, 146 (2d Cir. 2008) ("Actions of a private entity are attributable to the State if there is a sufficiently close nexus betwe
fendant also "`participat[ed] in the sexual abuse" of others. Id. A few days later, the press reported a statement by a spokesman for the defendant, Ross Gow. Among other things, 45 filed a corrected motion on January 2, 2015. See Doe, No. 08 Civ. 80736, Dkt. No. 280. The court later struck the original
s filed on September 21, 2015 at which time Plaintiff was living in Colorado and Defendant Ghislaine Maxwell was living in New York. Plaintiff is a United States Citizen. Plaintiff is seeking damages in excess of $75,000.00. Defendant's Statement: Ms. Maxwell agrees with the Plaintiff's statement, above. i
half of Ms. Maxwell. No further communication will be provided by her on this matter. 6 EFTA00792761 Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is o not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The origin
s filed on September 21, 2015 at which time Plaintiff was living in Colorado and Defendant Ghislaine Maxwell was living in New York. Plaintiff is a United States Citizen. Plaintiff is seeking damages in excess of $75,000.00. Defendant's Statement: Ms. Maxwell agrees with the Plaintiff's statement, above. i
half of Ms. Maxwell. No further communication will be provided by her on this matter. 6 EFTA00617401 Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is so not a new individual. The allegations made by against Ghislaine Maxwell are untrue. The original allegations a
elationship to each of these individuals. Defendant hired Jaffe, then of Cohen s Gresser LLP, to represent her in connection with legal matters in the United States at some indeterminate point in 2009. Def.'s Decl. of L.A. Menninger in Supp. Def.'s Resp. to Pl.'s Mot. to Compel Production of Does. Subject to Im
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 these individu
ions posed may be insufficient as a matter of law to support [a] perjury conviction." United States v. Lighte, 782 F.2d 367 (2d Cir. 1986); see also United States v. Bonacorsa, 528 F.2d 1218, 1221 (2d Cir. 1976). "Precise questioning is imperative as a predicate for the offense of perjury." Bronston v. United
le statement on behalf of Ms. Maxwell. No further communication will be provided by her on this matter. Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is so not a new individual. The allegations made by against Ghislaine Maxwell are untrue. The original allegations
ient acquiesced in this abuse, or that the abuse was OK because she was paid for it — leaves out the fact that this is why we have laws in the United States to protect minor children who are groomed and sexually trafficked by adults.’ Epstein served 13 months in a Florida prison after pleading guilty in
Page: HOUSE_OVERSIGHT_015529 →our client acquiesced in this abuse, or that the abuse was OK because she was paid for it — leaves out the fact that this is why we have laws in the United States to protect minor children who are groomed and sexually trafficked by adults.’ Epstein served 13 months in a Florida prison after pleading gui
Page: HOUSE_OVERSIGHT_015529 →tation that Giuffre’s factual reporting of what had happened to her would not be credited. 29. As part of Maxwell’s campaign she directed her agent, Ross Gow, to attack Giuffre’s honesty and truthfulness and to accuse Giuffre of lying. 30. On or about January 3, 2015, speaking through her authorized agent
Page: HOUSE_OVERSIGHT_015536 →Entities connected to both United States and Ross Gow

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
Prince Andrew
PERSON
Alan Dershowitz
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSON
New York
LOCATION
Marc Rich
PERSON
Donald Trump
PERSON
Bill Clinton
PERSON
Scarlett Johansson
PERSONDarren Indyke
PERSON
Julie K. Brown
PERSON
Virginia Giuffre
PERSONMaria Farmer
PERSONSouthern District
LOCATION