1320-20.pdf

"VIRGINIA L. GIUFFRE, Plaintiff v. GHISLAINE MAXWELL, Defendant."

"Defendant Ghislaine Maxwell (Ms. Maxwell) files this Response... Laura A. Menninger"

"Defendant Ghislaine Maxwell (Ms. Maxwell) files this Response... Jeffrey S. Pagliuca"

"HADDON, MORGAN, AND FOREMAN, P.C."

"GHISLAINE MAXWELL, Defendant."

"Ms. Maxwell fully testified for the entire 7 hours, responded to all questions posed to her"

"Plaintiff claims these statements are defamatory because she has been called a liar. Ms. Maxwell denied the allegations made stating they were untrue "

"Johanna Sjoberg (a former Epstein employee)... in her 5 plus years working for Mr. Epstein"

"Juan Alessi (a former Epstein employee)"

"David Rodgers (former Epstein Pilot)."

"Maria Alessi and Jo Fontanella (former Epstein household employees)"

"Maria Alessi and Jo Fontanella (former Epstein household employees)"

"former Palm Beach Detective Joe Recarey"

"former Palm Beach Police Chief Michael Reiter"

"filed in the Crime Victims’ Rights Act case on behalf of Plaintiff by her attorneys, Bradley Edwards and Paul Cassell."

"Ms. Maxwell requests that the Motion to permit in excess of the presumptive ten deposition limit be denied"

"Ms. Maxwell’s denial of the allegations made by Plaintiff about Plaintiff’s own interactions with Maxwell was defamatory"

"Attorneys for Ghislaine Maxwell Laura A. Menninger"

"Attorneys for Ghislaine Maxwell Jeffrey S. Pagliuca"

"Laura A. Menninger (LM-1374) HADDON, MORGAN AND FOREMAN, P.C."

"both men were involved in the investigation of Mr. Epstein and are expected to testify about their investigation."

"Plaintiff identifies Nadia Marcinkova, Sarah Kellen... and Jeffrey Epstein as alleged co-conspirators with each other."

"Plaintiff identifies Nadia Marcinkova, Sarah Kellen... and Jeffrey Epstein as alleged co-conspirators with each other."

"Emmy Taylor (identified as assistants to Ms. Maxwell or Mr. Epstein)."

"Emmy Taylor (identified as assistants to Ms. Maxwell or Mr. Epstein)."

"no other witness has claimed as Plaintiff does that Ghislaine Maxwell sexually abused them, sexually trafficked them"

"I certify that on June 6, 2016, I electronically served this Defendant’s Response... on the following: Sigrid S. McCawley"

"alleged modus operandi of the Epstein organization"

"The heart of Plaintiff’s argument is that Ms. Maxwell inconveniently testified and denied Plaintiff’s claims... Plaintiff identifies Nadia Marcinkova,"

"Maxwell persuaded Jane Doe # 3 (who was only fifteen years old) to come to Epstein's mansion . . . Plaintiff now concedes that she did not meet Ms. Ma"

"Epstein and his co-conspirators created opportunity, intent, plan, knowledge, and to the specifics that make up the criminal signature of Epstein and "

"The same holds true for Nadia Marcinkova, Sarah Kellen ... and Jeffrey Epstein, each of whom Plaintiff anticipates will ... invoke their Fifth Amendme"

"corroborate Ms. Giuffre's account description of the motive, way in which Epstein and his co-conspirators created opportunity"