EFTA00805057.txt

"From: Laura Menninger Sent: Tuesday, November 6.2018 5:55 PM To: Paul Cassell"

"On Nov 6, 2018, at 4:27 PM, Paul Cassell wrote: Hi Laura"

"Jane Doe 43 v. Jeffrey Epstein, et at"

"Jane Doe 43 v. Jeffrey Epstein, et at"

"compelling defendant Maxwell to produce requested documents"

"I write in connection with your client's, Ms. Maxwell's, recent discovery responses"

"Defendant Maxwell was for decades the highest-ranking employee of the Defendants' sex trafficking venture and enterprise"

"From: Paul Cassell Sent: Wednesday, November 14 2018 8:07 PM To: Laura Mennin er"

"my client's, [REDACTED], requests for production"

"Defendant Maxwell was for decades the highest-ranking employee"

"Defendants Epstein and Maxwell continued to provide Plaintiff with things of value"

"Maxwell's communications with Epstein "in and after 2007" are directly connected to these allegations in the Complaint."

"Dershowitz's communications with Ms. Maxwell are relevant."

"Ms. Maxwell's deep and long-running involvement in a sexual trafficking enterprise that involved trafficking females under the age of 18"

"alleges that she is a victim of Ms. Maxwell's and Mr. Epstein's sex trafficking enterprise"

"has alleged that Maxwell re atedly was involved in sexually trafficking her as part Epstein's sex trafficking enterprise"

"I will be with Ms Maxwell in her deposition on Nov 8"

"We write today to request a pre-motion conference... to seek the Court's guidance as to compelling defendant Maxwell to produce requested documents."

"plaintiff... has alleged that she was sexually trafficked by Jeffrey Epstein"

"plaintiff... has alleged that she was sexually trafficked by Jeffrey Epstein and his co-defendants, including defendant Ghislaine Maxwell"

"Defendant Maxwell was for decades the highest-ranking employee of the Defendants' sex trafficking venture and enterprise"

"Defendant Maxwell was for decades the highest-ranking employee of the Defendants' sex trafficking venture and enterprise"

"Defendants Epstein and Maxwell continued to provide Plaintiff with things of value in exchange for Plaintiff's continued compliance with Epstein's sex"

"Defendants Epstein and Maxwell continued to provide Plaintiff with things of value in exchange for Plaintiff's continued compliance with Epstein's sex"

"she was recruited an enticed into performing sex acts with Epstein as part of a larger enterprise"

"she was recruited an enticed into performing sex acts with Epstein as part of a larger enterprise to provide Epstein with young females for sex, in wh"

"Defendants actively concealed and covered up what they had done to Plaintiff and other similarly situated females. Defendant's coverup included effort"

"Defendants actively concealed and covered up what they had done to Plaintiff and other similarly situated females"

"All documents relating to payments made from Jeffrey Epstein or any related entity to any of the Defendants from 2000 — present"

"Defendants actively concealed and covered up what they had done to Plaintiff... included efforts to intimidate witnesses"

"Defendants actively concealed and covered up what they had done to Plaintiff... included efforts to intimidate witnesses"

"Paul G. Cassell Ronald N. Boyce Presidential Professor of Criminal Law and University Distinguished Professor of Law S.J. Quinney College of Law"