Epstein Secrets

Fifth Avenue, Suite 3100 New York, NY 10118 19. Ross Gow (video) 15 EFTA00792770 Acuity Representation 23 Berkeley Square London W1J 6HE 20. Brett Jaffe (live) Alston & Bird, LLP, NY 90 Park Avenue New York, NY 10016 21. Robert Hanson (live) 22. (live) do Philip Barden Devonshires Solicitors L

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

Al Gore 40. Ross Gow 41. Fred Graff 42. Philip Guderyon 43. REDACTED 44. Shannon Harrison 45. Stephen Hawking 46. 47. Brittany Henderson 48. Brett Jaffe 49. Michael Jackson 50. Carol Roberts Kess 51. Dr. Karen Kutikoff 52. Peter Listerman 53. George Lucas 54. Tony Lyons 55. Bob Meister 56. Jam

S! EFTA00143527 10:53* se ^•> Newsweek The names include: 1. Ghislaine Maxwell 2. 3. Prince Andrew of England 4. James Michael Austrich 5. Philip Barden 6. REDACTED 7. Cate Blanchett 8. David Boies 9. Laura Boothe 10. 11. Rebecca Boylan 12. Joshua Bunner 13. Naomi Campbell 14. 15. Paul Casse

W. Es lin, Ed.D. live) 17. Anthony Figueroa (video) 18. Louis Freeh (live) SE 19. Ross Gow (video) 15 EFTA00617410 Acuit Re resentation 20. Brett Jaffe (live) Alston & Bird, LLP, NY 90 Park Avenue New York, NY 10016 21. Robert Hanson (live) 23. Brittany Henderson (video) 24. Peter Kent live 25

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

014218708 5 March 2011 NOT FOR PUBLICATION Dear Annette Ghislaine Maxwell I represent Ghislaine Maxwell. I am in receipt of an email you sent to Brett Jaffe late yesterday calling for a response by noon today. Your email is represented as containing a number of questions, in relation to which you seek t

amation. You will appreciate that if you do publish untrue allegations my client will have no option but to protect her position. Yours sincerely Philip Barden Partner Page 2 4218708.1 EFTA_R1_00009779 EFTA01733841

citors Daniel Foggo Our Ref: PTBICLICA4218704 The Sunday Times 5 March 2011 Dear Daniel Ghislaine Maxwell I have received an email from you to Brett Jaffe. I represent Ghislaine Maxwell. The allegations to which you refer are all entirely untrue and without any factual basis. Ghislaine Maxwell was no

and in its heading that the allegations made by are vehemently denied and that action is going to be taken against the Daily Mail. Yours sincerely Philip Barden Partner Page 2 EFTA_R1_00010511 EFTA01733899

014218708 5 March 2011 NOT FOR PUBLICATION Dear Annette Ghislaine Maxwell I represent Ghislaine Maxwell. I am in receipt of an email you sent to Brett Jaffe late yesterday calling for a response by noon today. Your email is represented as containing a number of questions, in relation to which you seek t

amation. You will appreciate that if you do publish untrue allegations my client will have no option but to protect her position. Yours sincerely Philip Barden Partner Page 2 4218708.1 EFTA_R1_00010526 EFTA01733901

fully submitted. II. The Privilege Claims at Issue Defendant 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 summa

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

[email protected] 5 March 2011 NOT FOR PUBLICATION Dear Annette Ghislaine Maxwell I represent Ghislaine Maxwell. I am in receipt of an email you sent to Brett Jaffe late yesterday calling for a response by noon today. Your email is represented as containing a number of questions, in relation to which you seek

amation. You will appreciate that if you do publish untrue allegations my client will have no option but to protect her position. Yours sincerely Philip Barden Partner Page 2 4218708.1 EFTA00586262