…Defendant’s Resp. at 3. Tellingly, Defendant’s response brief cites no authority to refute that proposition that adverse inference can be drawn against co- conspirators. Presumably this is because, as recounted in Ms. Giuffre’s opening brief (at pp…
…Defendant’s Resp. at 3. Tellingly, Defendant’s response brief cites no authority to refute that proposition that adverse inference can be drawn against co- conspirators. Presumably this is because, as recounted in Ms. Giuffre’s opening brief (at pp…
…45 Ms. Giuffre is in possession of a responsive document that contains a confidentiality provision. If Defendant obtains, and produces to Ms. Giuffre, a written waiver from her co- conspirator, Mr. Epstein, of the confidentiality provision, freeing Ms. Giuffre from…
…was seeking Epstein’s permission with respect to her media communications regarding Ms. Giuffre shows a high level of coordination among these co-conspirators,2 and Ms. Giuffre should not be precluded from asking about critical communications because Defendant failed…
…has been working closely with Ms. Giuffre as her attorney for nearly two years on issues related to her sexual abuse by Jeffrey Epstein and his co-conspirators -- including active work in legal research and other aspects of this case…
…P . C. (212) 805 - 0300 Case 1:15-cv-07433-LAP Document 1325-18 Filed 01/04/24 Page 10 of 23 9 GlETGIUA 1 co-conspirators were also part of that plea agreement, that 2 non-prosecution agreement…
…Menninger Decl. Exhibit G shows an email chain containing six communications she had with , an alleged co-conspirator, yet only two of those emails were produced. The emails produced are in “screenshot” format rather than providing a complete production of…
…Defendant’s Resp. at 3. Tellingly, Defendant’s response brief cites no authority to refute that proposition that adverse inference can be drawn against co- conspirators. Presumably this is because, as recounted in Ms. Giuffre’s opening brief (at pp…
…Marcinkova was specifically identified by the U.S. Attorney’s Office for the Southern District of Florida as a “potential co-conspirator of Epstein” in the non- prosecution agreement it executed with Mr. Epstein as part of his guilty plea…
…There are a few groups of people, his office in New York and I guess -- *** Q. Okay. The other people mentioned as co-conspirators are Sarah Kellen, Adriana Ross, and Nadia Marcinkova. So we'll get to them in a…
…between Mr. Epstein and 12 the U.S. Attorney's office mentions people that are 13 called co-conspirators of Epstein. And Leslie Groff 14 is named as one of those co-conspirators. 15 …
…Marcinkova was specifically identified by the U.S. Attorney’s Office for the Southern District of Florida as a “potential co-conspirator of Epstein” in the non- prosecution agreement it executed with Mr. Epstein as part of his guilty plea…
…Defendant’s Resp. at 3. Tellingly, Defendant’s response brief cites no authority to refute that proposition that adverse inference can be drawn against co- conspirators. Presumably this is because, as recounted in Ms. Giuffre’s opening brief (at pp…
…Boston, MA 02116 Has knowledge of Defendant's conduct that is the subject of this action and knowledge of his sexual trafficking operation and other co-conspirators. 32. Tatiana Espinoza Address unknown at this time Telephone number unknown at this…
…1999, Jane Doe #3 was approached by Ghislaine Maxwell, one of the main women whom Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator in his sexual abuse and sex trafficking scheme. In fact…
…between Mr. Epstein and 12 the U.S. Attorney's office mentions people that are 13 called co-conspirators of Epstein. And Leslie Groff 14 is named as one of those co-conspirators. 15 …
…contains a confidentiality provision. As discussed during the March 21, 2016 meet and confer, If Defendant obtains, and produces to Ms. Giuffre, a written waiver from her co- conspirator, Mr. Epstein, of the confidentiality provision, releasing Ms. Giuffre from any…
…in the presence of young girls; • invocations of Fifth Amendment ri hts to remain silent b identified co-conspirators - when asked questions about whether with massages by young girls; • refusals by Jeffrey Epstein to discuss …
…Defendant’s Resp. at 3. Tellingly, Defendant’s response brief cites no authority to refute that proposition that adverse inference can be drawn against co- conspirators. Presumably this is because, as recounted in Ms. Giuffre’s opening brief (at pp…
…was convicted after a public trial; classes of victims have litigated public lawsuits against Jeffrey Epstein and his co-conspirators (including against several of his financial institutions); and the public and its elected officials have made uncovering details about Epstein…