…Doug Band, traveled on many more occasions.” The logs also showed Clinton traveled with other “employees and/or co-conspirators of Epstein’s that were closely connected to Epstein’s child exploitation and sexual abuse.” · “Jane Doe No. 102 stated…
…Plaintiff identifies Nadia Marcinkova, Sarah Kellen (a/k/a Sarah Kensignton or Sarah Vickers), and Jeffrey Epstein as alleged “co-conspirators” with each other. She requests the depositions of each. Plaintiff anticipates each will invoke the Fifth Amendment –in other…
…not entirely innocent third parties.”) (internal quotation omitted). As the Third Circuit has explained in declining to publicize a list of unindicted co- conspirators in a criminal case: The individuals on the sealed list are faced with more than mere …
…3, 2006, at A19 (discussing special non-prosecution agreement obtained by Epstein and his co- conspirators), so he continues to press to be treated differently than other witnesses in this case. Epstein cites no authority that would support barring videotaping…
…Office for the Southern District of Florida specifically identified both Kellen and Marcinkova as among four named “potential co- conspirators of Epstein” in the non-prosecution agreement it executed with Epstein as part of his guilty plea to Florida state…
…Epstein. 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…
…privilege. Additionally, these documents are relevant to the underlying litigation in their own right, as they show the nature of the ongoing relationship between Defendant and her co-conspirator, Jeffrey Epstein, and between and Defendant and Epstein’s close friend…
…refusal to accept service. See Mot. at 2 (“forced to personally serve the Defendant’s former boyfriend, employer, and co-conspirator”). As the timeline and documents now reveal, however, Plaintiff failed to provide notice to Ms. Maxwell that she was…
…15-cv-07433-LAP Document 76-2 Filed 03/31/16 Page 7 of 21 Has knowledge of Defendant’s conduct that is the subject of this action and knowledge of his sexual trafficking operation and other co-conspirators. 25…
…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…
…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 …
…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…
…Sarah Kellen and Nadia Marcincova, two other conspirators who (along with Defendant), helped Epstein in his sex abuse and sex trafficking efforts were also evading service. 2 Case 1:15-cv-07433-LAP Document 1331-13 Filed 01/05…
…12. 13. Ms. Maxwell denies that she was a co-conspirator of Epstein and is without knowledge or information sufficient to form a belief as to the remaining allegations contained in Paragraph 13. 14. Ms. Maxwell is without knowledge or…
…Menninger Decl. Exhibit G shows an email chain containing six communications she had with Natalia Malyshev, an alleged co-conspirator, yet only two of those emails were produced. The emails produced are in “screenshot” format rather than providing a complete…
…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…