Epstein Secrets

ever, the Court should be aware that DEs 165-3, 185-2 and 185-15 are pleadings that were stricken pursuant to Rule 12(0 by U.S. District Court Judge Marra and thus are not, as Plaintiff claims, "publicly available on the docket of Doe v. United States, 08-cv- 80736 (S.D.Fla.)." Resp. at 15 n.5. These t

, 39, and 49. DE 293, in its entirety. DONE AND ORDERED in chambers at West Palm Beach, Palm Beach County, Florida, this 611' day of April, 2015. KENNETH A. MARRA United States District Judge 10 EFTA00075003

cken pursuant to Rule 12(0 by U.S. District Court Judge Marra and thus are not, as Plaintiff claims, "publicly

fully submitted, /s/ Laura A. Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) Ty Gee (pro hac vice) Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver. CO 80203 Phone: Fax: Attorneys for Ghislaine Maxwell 21 EFTA00074984 Ca a:Mag0743tikIcAlPneDbt0rfiefiFO72

And 24 we have an order of the court by — Judge Marra 25 entered an order that we need to meet and co

tman. And 24 we have an order of the court by — Judge Marra 25 entered an order that we need to meet and co

u're holding the money, which 9 you're free to. But I don't know, even under the 10 best of circumstances and the best relationship 11 with Mr. Foreman, that I have the authority to 12 waive his fee. Arid that doesn't exist currently -- 13 certainly monetarily. So... 14 MR. JOSEPH GELLER: If I m

itles redacted consistent with Appellee's objections herein 5424 D Not a judicial document, not relied upon by Court; portions stricken by Judge Marra Florida Order I Not a judicial document, not relied upon by Court L Not a judicial document, not relied upon by Court; 3rd Party Confidentialit

, not relied upon by Court; portions stricken by Judge Marra Florida Order I Not a judicial document, not r

No. 18-2868 Appellee Maxwell's Response to Order to Show Cause EFTA00794214 Appellee Ghislaine Maxwell, through her attorneys Haddon, Morgan and Foreman, P.C., submits this Response to the Court's Order to Show Cause ("OTSC"). I. Objections to the Order to Show Cause. For the reasons stated in Ms.

m a pleading an insufficient defense or any redundant, immaterial, impertinent, or scandalous matter ... on its own,"" the Florida District Court (Kenneth A. Marra, Judge) sua sponte struck all allegations against additional parties from the pleadings, including those against Dershowitz, and therefore deni

s own,"" the Florida District Court (Kenneth A. Marra, Judge) sua sponte struck all allegations agains

olland & Knight LLP, Miami, FL, for Intervenors-Appellants Julie Brown and Miami Herald. Ty Gee (Adam Mueller, on the brief), Haddon, Morgan and Foreman, P.C., Denver, CO, for Defendant-Appellee Ghislaine Maxwell. Paul G. Cassell (Sigrid S. McCawley, Boies Schiller Flexner LLP, Ft. Lauderdale,

omitted). 6 EFTA00092313 defense or any redundant, immaterial, impertinent, or scandalous matter . . . on its own,"4 the Florida District Court (Kenneth A. Marra, Judge) .51112 sponte struck all allegations against additional parties from the pleadings, including those against Dershowitz, and therefore deni

its own,"4 the Florida District Court (Kenneth A. Marra, Judge) .51112 sponte struck all allegations aga

Holland & Knight LLP, Miami, FL, for Intervenors-Appellants Julie Brown and Miami Herald. TY GEE (Adam Mueller, on the brief), Haddon, Morgan and Foreman, P.C., Denver, CO, for Defendant-Appellee Ghislaine Maxwell. 3 EFTA00092310 PAUL G. CASSELL (Sigrid S. McCawley, Boies Schiller Flexner LLP, F

y Epstein 35266976 N/A 12./10t2013 MC2 Model Marra ement $29,440 SunTrust Bank Jeffrey Epstein 3

uthern Financial 42952771 N/A 1/12/2018 $150,000 Bank of America Southern Financial 42952771 Promissory note 2/2/2018 I laddon, Morgan and Foreman, P.C. (Ghislaine Maxwell)" $21,379 Wells Fargo Bank Darren K. Indyke PLLC 42953707 N/A 2/12/2018 Aviloop LLC'2 $40,000 TD Bank Jeffrey Ep

s in LM v. Jeffrey Epstein, 502008CA028051XXXXMB AB; EW v. Jeffrey Epstein, 502008CA028058XXXXMB AB; and Jane Doe v. Jeffrey Epstein, 08-80893- CIV Marra/Johnson; deposition of Jeffrey Epstein, p. 23, line 4; p. 38, line 22. R. 809-10, citing amended complaint in Razorback Funding, LLC, et al. v. Scot

rocess claims filed against Epstein by the appellant, Bradley J. Edwards. The trial judge relied in part upon the then binding precedent of Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013) (holding that the litigation privilege applies to causes of action for malicious prosecution and abuse of process

B; and Jane Doe v. Jeffrey Epstein, 08-80893-CIV Marra/Johnson. Rothstein returned to South Florida in

order granting summary judgment in favor of Epstein upon application of the litigation privilege based upon the then binding precedent of Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013). Final judgment was thereafter entered in favor of Epstein. Edwards appealed the judgment as it pertained to his

B; and Jane Doe v. Jeffrey Epstein, 08-80893- CIV Marra/Johnson. Rothstein returned to South Florida in

EFTA00583962 summary judgment in favor of Epstein upon application of the litigation privilege based upon the then binding precedent of Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013). Final judgment was thereafter entered in favor of Epstein. Edwards appealed the judgment as it pertained to his

ken by him occurred during the litigation of his abuse of process claim against Edwards. For support, he relies primarily on the decision of Wolfe v. Foreman, 2013 WL 3724763 (Fla. 3d DCA July 17, 2013), wherein the Third District found that the litigation privilege barred both an abuse of process claim a

lved and depended upon his plane travel. Although Judge Marra dismissed the RICO claim at some point in the fed

litigation. The RICO claim alleged that Epstein ran an expansive criminal entirpitge that involved and depended upon his plane travel. Although Judge Marra dismissed the RICO claim at some point in the federal litigation, the legal team representing ever clients intended to pursue an appeal of that dismi

at there was some improper coercion involved in, for example, Jane Doe’s case, his remedy was to raise the matter before Federal District Court Judge Kenneth A. Marra who was presiding over the matter. Far from raising any such claim, Epstein sinisly chose to settle that case. He is therefore now barred by the doct