Epstein Secrets

eclare as follows: 1. Iam an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. Iam a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit

things, like watch Sex And The City and eat popcorn. ‘A lot of it was very glamorous. | met famous friends of his such as Al Gore and Heidi Klum and Naomi Campbell. He introduced me as his “travelling masseuse.” Some people mistook me for his daughter. ‘When we were in New York or Palm Beach, Ghislaine and | wo

friends of his such as Al Gore and Heidi Klum and Naomi Campbell. He introduced me as his “travelling mas

rs, the same standard governs the addition of parties under Rule 21 and Rule 15. See Goston v. Potter, No. 08-cv-478 FJS ATB, 2010 WL 4774238, at *5 (N.D.N.Y. 2010) (citing Bridgeport Music, Inc. v. Universal Music Grp., Inc., 248 F.R.D. 408, 412 (S.D.N.Y. 2008)). 4 GIUFFRE002847 HOUSE_OVERSIGHT_014680

lorado. 7. Defendant Maxwell, who is domiciled in the Southern District of New York, is not a citizen of the state of Col

fre’s factual assertions as “entirely false” and “entirely untrue.” 32. Maxwell made the same false and defamatory statements as set forth above, in the Southern District of New York and elsewhere in a deliberate effort to maliciously discredit Giuffre and silence her efforts to expose sex crimes committed around the world by Maxw

ple in improper conduct, but just tell me what the names of the people are that you remember that you consider to be famous people. V: Ok, there was Naomi Campbell, Heidi Klum, there was Bill Clinton. There was Al (?) Gore, there was a whole bunch of models, I wouldn’t really honestly be able to give their names

u consider to be famous people. V: Ok, there was Naomi Campbell, Heidi Klum, there was Bill Clinton. The

s sexual trafficking victims in a case pending in the Southern District of Florida, specifically case no. 08-cv-80736- KA

things, like watch Sex And The City and eat popcorn. ‘A lot of it was very glamorous. | met famous friends of his such as Al Gore and Heidi Klum and Naomi Campbell. He introduced me as his “travelling masseuse.” Some people mistook me for his daughter. ‘When we were in New York or Palm Beach, Ghislaine and | wo

friends of his such as Al Gore and Heidi Klum and Naomi Campbell. He introduced me as his “travelling mas

eclare as follows: 1. Iam an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. Iam a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit

e when he was flying on the jet with us,’ Virginia says. ‘He laughed and did drawings of Bart and Homer for my little brother and my dad.‘Il also met Naomi Campbell at a birthday party of hers on a yacht in the South of France. She is a friend of Ghislaine’s but she was a real bitch to me. ‘She was ver