Epstein Secrets

oulevard, Suite 1200 Ft. Lauderdale, FL 33301 Tel: 954-356-0011 Fax: 954-356-0022 [email protected] University of Utah 383 University Street Salt Lake City, UT 84112 Tel: 801-585-5202 Fax: 801-585-2750 [email protected] Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman 425 North Andrews Avenue,

half of Ms. Maxwell. No further communication will be provided by her on this matter. 6 EFTA00792761 Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is o not a new individual. The allegations made by Victoria Roberts against Ghislaine Maxwell are untrue. The origin

Avenue, Suite 2 Fort Lauderdale, Florida 33301 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional

rized by you or authorized your agent(s) to make statements on your behalf in January of 2015. ANSWER: 2. Identify any action that you took after Ross Gow issued the January 2015 statement regarding Ms. to the public to retract or remediate the statement, clarify the statement, or otherwise cause a d

& FLEXNER. LLP Ft. Lauderdale. FL 33301 ME I FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN. P.L. Ft. Lauderdale. FL 33301 Paul G. Cassell Salt Lake City. UT 84112 s/ Laura A. Menninger Laura A. Menninger 24 EFTA00091376

ur legal fees concerning the above-captioned action, and all documents concerning the identity or identities of the individual(s) or entities paying Ross Gow, or any entities associated with Ross Gow, for any work he performed on Your behalf. RESPONSE: Ms. Maxwell objects to this Request on the grounds t

S, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 [email protected] Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 [email protected] J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 [email protected] /s/ Nicole Simmons Nicole Simmo

ilure to carry out the most elementary investigation or any real due diligence. Iam now taking action to clear my name," she said. Media contact: Ross Gow Acuity Reputation Tel: +44-203-008-7790 Mob: +44-7778-755-251 Email: [email protected] Media contact: Ross Gow, Acuity Reputation, Tel:

tation that Giuffre’s factual reporting of what had happened to her would not be credited. 29. As part of Maxwell’s campaign she directed her agent, Ross Gow, to attack Giuffre’s honesty and truthfulness and to accuse Giuffre of lying. 30. On or about January 3, 2015, speaking through her authorized agent

ssell Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah 332 South 1400 East, Room 101 = Salt Lake City, UT 84112-0730 Voice: 801-585-5202 Fax: 801-581-6897 Email: cassellp>@law.utah.edu You can access my publications on http://ssrn.com/author=30160

to a request to admit, specify in full the grounds for your objection. 4 EFTA00025472 --- PAGE BREAK --- REOUESTS FOR ADMISSION 1. Admit that Ross Gow was authorized by You or your agents to make statements to the public on your behalf. 2. Admit that Acuity Reputation was authorized by You or you

Avenue, Suite 2 Fort Lauderdale, Florida 33301 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional