Epstein Secrets

STRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff. v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S OPPOSITION TO MESSRS. CASSELL AND EDWARDS' RENEWED MOTIONS TO APPEAR PRO HAC VICE Defendant Ghislaine Maxwell, by and through her attorneys, hereby submits the following opposi

he supplements] over to the defense," the Plaintiff and pro hac vice applicants Cassell and Edwards filed with the Court: • at 5:33 p.m. Motion for Paul G. Cassell to Appear Pro Hac Vice (Doc. #112), which referenced "supplemental materials submitted at the hearing today"; EFTA00605448 • at 5:59 p.m., Letter

Court," as referenced in Motion for Paul Cassell to Appear (Doc. #112), because defense counsel had not received any such supplemental materials. [Menninger Decl. Ex. A]. Ms. McCawley responded that her "staff is scanning them to you now. You should have them shortly." Id. At 5:49 p.m., Plaintiff's counsel se

t Of Motion In Limine To Exclude In Toto Certain Depositions Designated By Plaintiff For Use At Trial via ECF on the following: Sigrid S. McCawley Paul G. Cassell Meredith Schultz 383 S. University Street BOLES, SCHILLER & FLEXNER, LLP Salt Lake it UT 4112 401 East Las Olas Boulevard, Ste. 1200 Ft. Laude

CF on the following: Sigrid S. McCawley Paul G. Cassell Meredith Schultz 383 S. University Street BOLE

threats to people on the telephone? MR. PAGLIUCA: Object to form and foundation. 3 EFTA00595615 THE WITNESS: Yes. He wasn't always friendly See Menninger Decl., Ex. F, 10:6-14; 43:15-44:4 As explained in in Wright & Miller, Federal Practice and Procedures, the use of a document during testimony to refresh

Sigrid S. McCawley Meridith Schultz Boors, SCHILLER & FLEXNER, LLP Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FiSTOS & LEHRMAN, P.L. Paul G. Cassell 383 S. University Street J. Stanley Pottinger SIM Is/ Nicole Simmons Nicole Simmons 10 EFTA00097405

intiff by her attorneys, Bradley Edwards and Paul Cassell. Menningcr DecL, Ex. A, p. 4. The very first lin

ached by Ghislaine Maxwell," and continuing that "Maxwell persuaded Jane Doe 143 (who was only fifteen years old) to come to Epstein's mansion ..." Menninger Decl., N. A at 26-29. No amount of "circumstantial evidence" can overcome the fact that Ms. Maxwell's statement was correct and that statements in the Jo