Epstein Secrets

ney Bruce Reinhart's involvement in and/or awareness of the Government's • • witness, subject, or t ' investigation, includin Ghislaine Maxwell, Lesley Groff, Larry Morrison, Larry Visoki, David Rogers, William Hammond, and Robert Roxburgh; c) All documents, correspondence, and other information reflect

nvestigation, includin Ghislaine Maxwell, Lesley Groff, Larry Morrison, Larry Visoki, David Rogers, Wil

e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. No. 17 Civ. 00616 (JGK) EFFREY EP. TEIN, GHISLAINE MAXWELL, LESLEY GROFF and Defendants. PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION OF GHISLAINE MAXWELL PLEASE TAKE NOTICE THAT, pursuant to Rule 30 of the Feder

JGK) EFFREY EP. TEIN, GHISLAINE MAXWELL, LESLEY GROFF and Defendants. PLAINTIFF'S NOTICE OF TAKING VI

LEY GROFF and Defendants. PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION OF GHISLAINE MAXWELL PLEASE TAKE NOTICE THAT, pursuant to Rule 30 of the Federal Rules of Civil Procedure, counsel for Plaintiff, will take a videotaped deposition of the Defendant as set forth below: NAME: Ghislaine Maxwell DATE AND TIME:

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and Defendants. No. 17 Civ. 00616 (JGK) PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION OF PLEASE TAKE NOTICE THAT, pursuant to Rule 30 of th

v. JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and Defendants. No. 17 Civ. 00616 (JGK) PLAINT

FF and Defendants. No. 17 Civ. 00616 (JGK) PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION OF PLEASE TAKE NOTICE THAT, pursuant to Rule 30 of the Federal Rules of Civil Procedure, counsel for Plaintiff, Defendant as set forth below: NAME: DATE AND TIME: LOCATION: will take a videotaped deposition of the August

roups, associations, organizations or any other legal or business entity. 8. "You" or "Your" hereinafter means Ghislaine Maxwell, Jeffrey Epstein, Lesley Groff, =, and any alias, employee, agent, attorney, consultant, related entities or other representative of Ghislaine Maxwell, Jeffrey Epstein, Lesley G

STED DOCUMENT REQUEST NO. 1 (Directed to All Defendants) A copy of your passport from 2000-2008. DOCUMENT REQUEST NO. 2 (Directed to Maxwell, and Groff) All documents relating to communications with Jeffrey Epstein from 1999 — present. DOCUMENT REQUEST NO. 3 (Directed to All Defendants) All docume

ntiff, by and through her undersigned counsel, hereby propounds Plaintiff's First Request for Production of Documents pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure to the Defendants. The responses are due at the offices of Boies Schiller Flexner LLP, 575 Lexington Avenue, 7th Floor, New York, NY 1002

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. No. 17 Civ. 00616 (JGK) JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and Defendants. PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN PLEASE TAKE NOTICE THAT, pursuant to Rule 30 of the Federal

JGK) JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and Defendants. PLAINTIFF'S NOTICE OF TAKING VI

ESLEY GROFF and Defendants. PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN PLEASE TAKE NOTICE THAT, pursuant to Rule 30 of the Federal Rules of Civil Procedure, counsel for Plaintiff, will take a videotaped deposition of the Defendant as set forth below: NAME: Jeffrey Epstein DATE AND TIME:

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. No. 17 Civ. 00616 (JGK) JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and Defendants. PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION OF LESLEY GROFF PLEASE TAKE NOTICE THAT. pursuant to Rule 30 of the Federal Ru

JGK) JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and Defendants. PLAINTIFF'S NOTICE OF TAKING VI

LESLEY GROFF and Defendants. PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION OF LESLEY GROFF PLEASE TAKE NOTICE THAT. pursuant to Rule 30 of the Federal Rules of Civil Procedure, counsel for Plaintiff, will take a videotaped deposition of the Defendant as set forth below: NAME: Lesley Groff DATE AND TIME: Aug

JGK) JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and Defendants. PLAINTIFF'S RE-NOTICE OF TAKING

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. No. 17 Civ. 00616 (JGK) JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and Defendants. PLAINTIFF'S RE-NOTICE OF TAKING VIDEOTAPED DEPOSITION OF LESLEY GROFF PLEASE TAKE NOTICE THAT. pursuant to Rule 30 of the Federal

ESLEY GROFF and Defendants. PLAINTIFF'S RE-NOTICE OF TAKING VIDEOTAPED DEPOSITION OF LESLEY GROFF PLEASE TAKE NOTICE THAT. pursuant to Rule 30 of the Federal Rules of Civil Procedure, counsel for Plaintiff, will take a videotaped deposition of the Defendant as set forth below: NAME: Lesley Groff DATE AND TIME: Oct

rd. Michael Miller Justin Y.K Chu Michael A. Keough STEPTOE & JOHNSON LLP Scott J. Link LINK & ROCKENBACH PA Counsel for Jeffrey Epstein, and Lesley Groff Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. Counsel for Ghislaine Maxwell By: /s/ Sigrid McCawley Sigrid McC

616 (1OK) JEFFREY EPSTEIN, GHISLAINE MAXWELL, Y GROFF and Defendants. PLAINTIFF'S RE-NOTICE OF TAKING

Y GROFF and Defendants. PLAINTIFF'S RE-NOTICE OF TAKING VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN PLEASE TAKE NOTICE THAT, pursuant to Rule 30 of the Federal Rules of Civil Procedure, counsel for Plaintiff, will take a videotaped deposition of the Defendant as set forth below: NAME: DATE AND TIME: LOCATION: Jeffre

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. No. 17 Civ. 00616 (JGK) JEFFREY EPSTEIN, GHISLAINE MAXWELL, pi...LESLEY GROFF and SHEV, Defendants. PLAINTIFF'S RE-NOTICE OF TAKING VIDEOTAPED DEPOSITION OF GHISLAINE MAXWELL PLEASE TAKE NOTICE THAT, pursuant to Rule 30 of

JEFFREY EPSTEIN, GHISLAINE MAXWELL, pi...LESLEY GROFF and SHEV, Defendants. PLAINTIFF'S RE-NOTICE OF

and SHEV, Defendants. PLAINTIFF'S RE-NOTICE OF TAKING VIDEOTAPED DEPOSITION OF GHISLAINE MAXWELL PLEASE TAKE NOTICE THAT, pursuant to Rule 30 of the Federal Rules of Civil Procedure, counsel for Plaintiff, will take a videotaped deposition of the Defendant as set forth below: NAME: Ghislaine Maxwell DATE AND TIME:

reports outlined the allegations underlying the NPA and to varying degrees detailed the involvement of Epstein's alleged co-conspirators, including Lesley Groff, Sarah Kellen, and Nadia Marcinkova. Some articles reported that Kellen and Marcinkova had invoked their Fifth Amendment right against self-incrimi

stein's alleged co-conspirators, including Lesley Groff, Sarah Kellen, and Nadia Marcinkova. Some articl

e other Class members. 284. This action has been brought and may properly be maintained as a class action against JP Morgan pursuant to Rule 23 of the Federal Rules of Civil Procedure because there is a well-defined community of interest in the litigation and the proposed Class is easily ascertainable from JP Morgan's r