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

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

wrote: I didn't do a statement. Want me lawyer to talk to your a come up with something. + I need to distance myself probably from you in some way. Barden my lawyer is going to call yours today. Who or what is Kathy?? What gossip. Helps me to know if you cab share plse. See bellow. THE TERRAMAR PROJEC

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

nswers saying this is test of the epstein phone system I have changed my plans and will meet with her Tues..I think this is best I will also get to Barden to ask for an extension so we can explore the best way forward. Everyone I have talked to says this gets tossed..I would rather have it tossed than

714353 dont you have a new york laweyr , not laura On Thu, Oct 8, 2015 at 4:31 PM, G Maxwell <GMaxl(aellmax.com> wrote: You mean laura menniger? Barden already called.. THE TERRAMAR PROJECT From: J lep Date: Thursday, October 8, 2015 at 13:31 PM To: G G Subject: Fwd: 5ok retainer Forwarded m

From: G Maxwell Sent: Thursday, October 8, 2015 8:31 PM To: jeffrey E. Subject: Re: Attachments: image001jpg You mean laura menniger? Barden already called.. THE TERRAMAR PROJECT <http://theterramarproject.org/> From: J Jep Date: Thursday, October 8, 2015 at 13:31 PM To: GG Subject: F

l Subject: Re: dont you have a new york laweyr , not laura On Thu, Oct 8, 2015 at 4:31 PM, G Maxwell a <mailtc wrote: You mean laura menniger? Barden already called.. THE TERRA=AR PROJECT <http://theterramarproject.org/> From: J Jep Date: Thursday, October 8, 2015 at =3:31 PM EFTA_R1_02009280

M To: G Maxwell Subject: Re: dont you have a new york laweyr , not laura On Thu, Oct 8, 2=15 at 4:31 PM, G Maxwell < You mean laura menniger? Barden already called.. THE TERRA=AR PROJECT <http://theterramarproject.org/> From: J Jep Date: Thursday, October 8, 2015 at =3:31 PM To: GG Subject: F

G Maxwell Subject: Re: dont you have a new york laweyr , not laura On Thu, Oct 8, 2015 at 4:31 PM, G Maxwell a wrote: You mean laura menniger? Barden already called.. THE TERRA=AR PROJECT <http://theterramarproject.org/> From: J Jep Date: Thursday, October 8, 2015 at =3:31 PM EFTA_R1_01603125

From: Ghislaine Sent: Wednesday, April 22, 2015 9:46 PM To: Jeffrey E. Subject: Re: ATTORNEY-CLIENT PRIVILEGE I would like Barden to reply to one further allegation in this bullshit She says Epstein and Maxwell asked her > to have a child for them and to sign a document signin

From: G Maxwell Sent: Friday, January 23, 2015 3:13 PM To: 1 Jep Subject: FW: Barden Spoke with Philip this Am. He will get first deliverable (questions ) to you over weekend and analysis of VR statements next week. 1 EFTA_R1_0133

2015 9:58 PM To: Ghislaine Subject: Re: ATTORNEY-CLIENT PRIVILEGE ok On Wed, Apr 22, 2015 at 5:46 PM, Ghislaine <mailto wrote: I would like Barden to reply to one further allegation in this bullshit She says Epstein=and Maxwell asked her > to have a child f=r them and to sign a document signin

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

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

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

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

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