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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
expected and intended, 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 thir
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
expected and intended, 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 thir
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
dant has withheld 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 e
Entities connected to both United States and Philip Barden

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
Bill Clinton
PERSONMaria Farmer
PERSON
Virginia Giuffre
PERSONSouthern District
LOCATIONMartin Weinberg
PERSON
Paul Cassell
PERSON
Alfredo Rodriguez
PERSONEmmy Taylor
PERSON
Colorado
LOCATION
Wilbur Ross
PERSON
United Kingdom
LOCATION
Vicky Ward
PERSON
David Rodgers
PERSONScott Rothstein
PERSON