Epstein Secrets

y know about it. Because the interview with the reporter is actually containeci in the FBI statement. MS. McCAWLEY: Good morning, your Honor. It's Sigrid McCawley on behalf of Your Honor, this is not some obscure document that the Court would not recognize. I'd like to pass up some copies for your

rk, N.Y. March 31, 2017 12:08 p.m. HON. ROBERT W. SWEET, District Judge APPEARANCES BOIES, SCHILLER & FLEXNER LLP Attorneys for Plaintiff BY: SIGRID S. McCAWLEY, ESQ. MEREDITH L. SCHULTZ, ESQ. S.J. QUINNEY COLLEGE OF LAW AT THE UNIVERSITY OF UTAH For Plaintiff BY: PAUL G. CASSELL, ESQ. FARMER, JAFFE, WEI

EXNER LLP Attorneys for Plaintiff BY: SIGRID S. McCAWLEY, ESQ. MEREDITH L. SCHULTZ, ESQ. S.J. QUINNEY CO

hey have the burden of proving that what Ms. Maxwell said was false. That's what is at issue. We have to look at Ms. Maxwell's statement issued by Barden and Gow and then go backwards from there. And the burden on the plaintiff is proving falsity of that statement. It is not the situation where -- wh

t. X APpEARANCE S: Counsel for Plaintiffs BOEIS, SCHILLER & FLEXNER LLP 401 East Las Olas Boulevard, Suite 1200 Fort Lauderdale, FL 33301 By: Sigrid S. McCawley, Esq. Meredith L. Schultz, Esq. Counsel for Defendants HADDON, MORGAN AND FOREMAN, P.C. 150 East Tenth Avenue Denver, CO 80203 By: Laura A. Hen

ed -a cease and 0 "Plaintiff's Document Request No. 17: All documents relating to communications with [Defendant) and Ross Gow from 2005-Present." McCawley,Decl, in Supp„,,Consoiidated Reply in Supp. Hot. to Compel Production of Docs. Subject to Improper Objections and Improper Claim of Priv., ECF No.

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 each of th

on January 6, 2015, #1030-43. c. Jaffe on March 15, 2011, #1000-19.2 Gow on January 2, 2011, #1020-26. Gow and Basham on January 2, 2015, #1027- Barden #1059-83, Some emails were forwarded or carbon copied ("CC'd") later in the chain, leading to some overlap and duplication. Whether one party or

R LLP 15 Attorneys for Plaintiff BY: SIGRID S. McCAWLEY, ESQ. 16 MEREDITH L. SCHULTZ, ESQ. 17 S.J. QU

.m. 10 Before: 11 HON. ROBERT W. SWEET, 12 District Judge 13 APPEARANCES 14 BOIES, SCHILLER & FLEXNER LLP 15 Attorneys for Plaintiff BY: SIGRID S. McCAWLEY, ESQ. 16 MEREDITH L. SCHULTZ, ESQ. 17 S.J. QUINNEY COLLEGE OF LAW AT THE UNIVERSITY OF UTAH For Plaintiff 18 BY: PAUL G. CASSELL, ESQ. 19 FA

t it. 14 Because the interview with the reporter is actually contained 15 in the FBI statement. 16 MS. McCAWLEY: Good morning, your Honor. It's Sigrid 17 McCawley on behalf of 18 Your Honor, this is not some obscure document that the 19 Court would not recognize. I'd like to pass up some copie

the burden of proving that what Ms. Maxwell said was false. 16 That's what is at issue. We have to look at Ms. Maxwell's 17 statement issued by Barden and Gow and then go backwards from 18 there. And the burden on the plaintiff is proving falsity of 19 that statement. It is not the situation whe

s Trial Counsel: David Boies: Boies Schiller & Flexner 333 Main Street Armonk, NY 10504 Tel: 914-749-8200 Fax: 914-749-8300 [email protected] Sigrid McCawley: Boies Schiller & Flexner 401 E. Las Olas Boulevard, Suite 1200 Ft. Lauderdale, FL 33301 Tel: 954-356-0011 Fax: 954-356-0022 [email protected]

200 Fax: 914-749-8300 [email protected] Sigrid McCawley: Boies Schiller & Flexner 401 E. Las Olas Boule

d, 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 thirty members of

Main Street Armonk, NY 10504 Tel: Fax: Sigrid McCawley: Boies Schiller & Flexner 401 E. Las Olas Boule

and Fax Numbers of Trial Counsel: Plaintiff's Trial Counsel: David Boies: Boies Schiller & Flexner 333 Main Street Armonk, NY 10504 Tel: Fax: Sigrid McCawley: Boies Schiller & Flexner 401 E. Las Olas Boulevard, Suite 1200 Ft. Lauderdale, FL 33301 Tel: Fax: EFTA00617396 Meredith Schultz: Paul Casse

d, 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 thirty members of

liability case. 4 MR. CASSELL: Right. So Epstein was the one who 5 provided the loan to get that -- 6 THE COURT: Says who? 7 MR. CASSELL: Ms. McCawley, who took Maxwell's 8 deposition, is advising me that during Maxwell's deposition, 9 she conceded that. 10 THE COURT: Well, all right. Okay. Bu

fered for the truth of 5 the matter asserted, we want to offer it to show Ms. Maxwell's 6 state of mind when she issued her statement through Mr. Barden 7 and Mr. Gow. So the huge problem with that, your Honor, which 8 we've already dealt with, is, Ms. Maxwell has no knowledge of 9 what's in the

ts into the liability case. MR. CASSELL: Right. So Epstein was the one who provided the loan to get that -- THE COURT: Says who? MR. CASSELL: Ms. McCawley, who took Maxwell's deposition, is advising me that during Maxwell's deposition, she conceded that. THE COURT: Well, all right. Okay. But that isn

fered for the truth of 5 the matter asserted, we want to offer it to show Ms. Maxwell's 6 state of mind when she issued her statement through Mr. Barden 7 and Mr. Gow. So the huge problem with that, your Honor, which 8 we've already dealt with, is, Ms. Maxwell has no knowledge of 9 what's in the

, I don't see how that gets MR. CASSELL: Right. So Epstein was the one who provided the loan to get that -- THE COURT: Says who? MR. CASSELL: Ms. McCawley, who took Maxwell's deposition, is advising me that during Maxwell's deposition, she conceded that. THE COURT: Well, all right. Okay. But that isn'

ing offered for the truth of the matter asserted, we want to offer it to show Ms. Maxwell's state of mind when she issued her statement through Mr. Barden and Mr. Gow. So the huge problem with that, your Honor, which Ww ' ve already dealt with, is, Ms. Maxwell has no knowledge of what's in these poli