Epstein Secrets

ere confidential.[-13-11E031. vaarr. S. .4 PNWN Ili 4 Epstein was accused of sex trafficking of minors at his mansion_ at 9 East 71st Street. Maria Farmer v. Epstein and Maxwell (2019) itc-rtM - FIRST SoCAL. IPPoe-vic -Peace Crrice:k - It `/RS CC.-O gADINF) On April 16, 2019, Maria Fanner went public

in New York, alleging that she and her 15-year-old sister, Annie, had been sexually assaulted by Epstein and Maxwell in separate locations in 1996. Farmer met Epstein and Maxwell at her graduate art gallery reception at the New York Academy of Art in 1995. The following year, in the summer of 1996, th

GET( (•-t f GIZGOMIK)Ci OF- VI Cr II RO0 7 "" 2009 caNkice-nows Hects AN1Ca.3 - iDAQ(ID isRptotEN-1 • Supplied my phone number to Patricia and Maria who started threatening phone text msgs when he was away from the home working at the mines - death threats against me and my family and infidelity

nd Circuit.M On March 11, 2019, in the appeal of the district judge's refusal to unseal the documents relating to the 2017 defamation settlement of Giuffre v. Maxwell, the Second Circuit Court gave parties one week to provide good cause as to why they should remain under seal, without which they would be unsealed

FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L.

17 TO: Honorable John G. Koeld FAX NO: FROM: Maria Kelljchian RE: Jane Doe 43 v. Jeffrey Epstein

. Koelti July 17, 2017 Page 2 With regard to Epstein's request that he be given leave to move for modification of the protective order entered in Giuffre v. Maxwell, No. 15 Civ. 7433 (RWS), any issues related to the protective order are properly addressed to Judge Sweet. See, e.g., Daniels v. City of N. Y., 200

bail request was opposed by alleged victim Annie Farmer. 120 On 19 January 2021, a court hearing was dis

y / secrete D mg invotement - narcotics Previous condiiirCtvi lfki iffaTeTrAtelatde— _ EFTA00266199 • Supplied my phone number to Patricia and Maria who started threatening phone text msgs when he was away from the home working at the mines - death threats against me and my family and infidelity

ircuit.1i531 On March it, 2019, in the appeal of the district judge's refusal to unseal the documents relating to the 2017 defamation settlement of Giuffre v. Maxwell, the Second Circuit Court gave parties one week to provide good cause as to why they should remain under seal, without which they would be unsealed

at 61-62. However, although the line prosecutor, Maria Villafaiia, subsequently sent the CEOS Chief a d

as aware, Doe v. Indyke was the "lone case in this District that has not yet been either resolved or stayed at this point. . . In 23 In particular, Giuffre v. Maxwell was resolved in 2017 and the determination of what material should remain sealed remains the only open issue. Accordingly, there is no more discover

by a stay in the Doe case because the outcome of the criminal case could resolve disputed issues in the Doe case. Such concerns are not present in Giuffre v. Maxwell. 57 EFTA00077689 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine M

d following the development of a full factual record. See, e.g., Strohm, 671 at 1175 (appeal following conviction); SanvaH, 669 F.3d at 406 (same); Farmer, 137 F.3d at 1269 (appeal following conviction and partial Rule 29 dismissal) Marldewicz, 978 F.2d at 808 (appeal following conviction); cf. United

on in ordering the unsealing of the deposition materials and that Maxwell's interests outweighed the public's interests in access to the materials. Giuffre v. Maxwell, No. 20-2413 (2d Cir.), (Dkt. No. 140-1 at 2). On October 19, 2020, the Second Circuit found that Judge Preska "correctly held that the deposition m

on a motion to dismiss without the benefit of the full factual record. The motion should be denied. allegations that were central to the dispute in Giuffre v. Maxwell." (Def. Mot. 4, Ex. I at 7:3-6.) (The last colloquy has been unsealed except for Minor Victim-2's name. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1).)

at 61-62. However, although the line prosecutor, Maria Villafaiia, subsequently sent the CEOS Chief a d

as aware, Doe v. Indyke was the "lone case in this District that has not yet been either resolved or stayed at this point. . . In 23 In particular, Giuffre v. Maxwell was resolved in 2017 and the determination of what material should remain sealed remains the only open issue. Accordingly, there is no more discover

by a stay in the Doe case because the outcome of the criminal case could resolve disputed issues in the Doe case. Such concerns are not present in Giuffre v. Maxwell. 57 EFTA00039504 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine M

d following the development of a full factual record. See, e.g., Strohm, 671 at 1175 (appeal following conviction); SanvaH, 669 F.3d at 406 (same); Farmer, 137 F.3d at 1269 (appeal following conviction and partial Rule 29 dismissal) Marldewicz, 978 F.2d at 808 (appeal following conviction); cf. United

on in ordering the unsealing of the deposition materials and that Maxwell's interests outweighed the public's interests in access to the materials. Giuffre v. Maxwell, No. 20-2413 (2d Cir.), (Dkt. No. 140-1 at 2). On October 19, 2020, the Second Circuit found that Judge Preska "correctly held that the deposition m

on a motion to dismiss without the benefit of the full factual record. The motion should be denied. allegations that were central to the dispute in Giuffre v. Maxwell." (Def. Mot. 4, Ex. I at 7:3-6.) (The last colloquy has been unsealed except for Minor Victim-2's name. (See 15 Civ. 7433 (LAP), Dkt. No. 1212-1).)

potential co- conspirators of Epstein" evolved from a more narrow provision sought by the defense. The provision expanded as [USAO-SDFL prosecutor Maria] Villafana and defense counsel exchanged drafts of, first, a proposed federal plea agreement and, then, of the NPA, with apparently little analysis

stayed at this point. . . In particular, this matter appears to be the only remaining active civil case in this District in which 23 In particular, Giuffre v. Maxwell was resolved in 2017 and the determination of what material should remain sealed remains the only open issue. Accordingly, there is no more discover

by a stay in the Doe case because the outcome of the criminal case could resolve disputed issues in the Doe case. Such concerns are not present in Giuffre v. Maxwell. 57 EFTA00095149 claims against Ghislaine Maxwell have been asserted." (20 Civ. 484 (DCF) (JGK), Dkt. No. 80 at 2). The defendant's baseless con

Defendants JEFFREY EPSTEIN & LESLEY GROFF To: FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L

laid in the Southern District of New York. Finally, Plaintiff's deposition testimony, and the documents that she produced, in the action captioned Giuffre v. Maxwell, No. 15 Civ. 7433 (RWS) (the "Giuffre action") further demonstrate that the FAC should be dismissed for the reasons set forth above and in the Defi

an employee of Epstein responsible for manning the front door at his New York mansion and keeping records of people who came to the home. (a) Ms. Farmer witnessed a number of school-age girls coming to the house; some of the young girls would be wearing their school uniforms and would be escorted up

e. She's made up the whole story. There is no truth to it." (t) August 12, 2019, in a press statement issued after the Second Circuit's ruling in Giuffre v. Maxwell: "She invented the false accusation against me only in 2014, when her lawyers `pressured' her to do so for financial reasons."2° (u) August 30, 201