EFTA00622175.txt

"defendant and non-party witness Epstein have had — and continue to have — a close relationship. Indeed, they were sexually intimate for a number of ye"

"From: jeffrey E. [email protected] Sent Thursday, January 15, 2015 5:27 PM To: Gmax do you want shwIly to come out and say she was the girlfriend"

"Sigrid McCawley BOLES, SCHILLER & FLEXNER LLP ... Plaintiff respectfully submits her reply"

"Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-RWS"

"Defendant and Epstein are operating together under a Joint Defense Agreement in this case."

"From: Jeffrey E. Sent Wednesday, January 21, 2015 4.47 PM To: G Maxwell Subject FW Guardian"

"I regularly flew on Jeffrey Epstein's airplane"

"Jeffrey Epstein's home in New York"

"Plaintiff, v. Ghislaine Maxwell, Defendant."

"the foregoing document is being served this day on the individuals identified below... Laura A. Menninger, Esq."

"the foregoing document is being served this day on the individuals identified below... Jeffrey Pagliuca, Esq."

"I am a Partner with the law firm of Boies, Schiller & Flexner LLP"

"Ghislaine Maxwell, Defendant. Case No.: 15-cv-07433-RWS"

"Attached hereto as Sealed Exhibit 2 is a true and correct copy of Excerpts from September 9, 2016, Deposition of Jeffrey Epstein."

"living with her at Defendant and Epstein's various residences... his joint-defense partner"

"On or about March 9th, 2001, you, the Defendant in this case, Ms. Maxwell, Emmie M, and flew on your private jet from Tangier to Luton"

"On or about March 9th, 2001, you, the Defendant in this case, Ms. Maxwell, Emmie M, and flew on your private jet from Tangier to Luton"

"On or about March 9th, 2001, you, the Defendant in this case, Ms. Maxwell, Emmie M, and flew on your private jet from Tangier to Luton"

"photograph taken showing Prince Andrew, and Defendant all standing close together in what appears to be Defendant's London apartment"

"this defamation action revolves around whether Epstein and Defendant were involved in a conspiracy"

"she was sexually trafficked by Jeffrey Epstein and his girlfriend, Defendant Maxwell"

"Defendant argues that Epstein was the boss and she was only his lieutenant... sex trafficking conspiracy that had Epstein at the top and Defendant has"

"Defendant and Epstein were first intimate sexual partners"

"allegations that she was sexually trafficked by both Epstein and Defendant"

"allegations that she was sexually trafficked by both Epstein and Defendant"

"Jeffrey Epstein's airplane"

"had said that she was being sexually trafficked by Epstein and Defendant"

"evidence demonstrating that Defendant was involved in the sex trafficking scheme"

"criminal sex trafficking enterprise with Epstein at its head and Defendant as his trusted lieutenant or Madame"

"Defendant professed to be unable to recall critical events — such as flying more than twenty times with then [REDACTED] on Epstein's private plane"

"Defendant called him to ask if he had found other girls to bring to Jeffrey... asking her to get girls, or asking me to get girls."

"she was sexually trafficked by both Epstein and Defendant"

"she was sexually trafficked by both Epstein and Defendant"

"Epstein at the top and Defendant has his trusted lieutenant"

"flight logs showing her repeatedly flying interstate and internationally on Epstein's private jet"

"Were you ever in a room with Prince Andrew in New York in Jeffrey Epstein's home"

"both defendant and Epstein working closely together on crafting a public statement"

"alleges Epstein and Defendant sexually trafficked her to Prince Andrew"

"alleges Epstein and Defendant sexually trafficked her to Prince Andrew"

"Epstein flew to London on March 9, 2001, with Defendant"

"Epstein flew to London on March 9, 2001, with Defendant"

"Epstein met Prince Andrew in March 2001 in London"

"Did you meet Prince Andrew, the Duke of York, in about March of 2001 in London?"

"it is likely that Defendant has either destroyed or willfully withheld many other emails, both with Jeffrey Epstein and other key witnesses"

"Epstein had enough of a dog in this fight to offer to have Shelley come forward to lie and pretend to have been his girlfriend"

"asking [REDACTED] to sit on Prince Andrew's lap with the caricature of Prince Andrew"

"living with her at Defendant and Epstein's various residences"

"feigning convenient memory lapses whenever difficult questions were posed to her during the deposition"