gov.uscourts.nysd.447706.1330.22.pdf

Case 1:15-cv-07433-LAP Document 1330-22 Filed 01/05/24 Page 1 of 22 EXHIBIT D  Case 1:15-cv-07433-LAP Document 1330-22 Filed 01/05/24 Page 2 of 22 From: G Maxwell <[email protected]> Sent: Sunday, January 11, 2015 6:26 AM To: JJep Subject: Fw: THE TERRAMAR PROJECT FACEBOOK TWITTER G+ PINTEREST INSTAGRAM PLEDGE THE DAILY CATCH From: Philip Barden Sent: Sunday, 11 January 2015 05:27 To: Cc: G Maxwell Subject: Re: Saying nothing is reputational suicide. Even if AR is discredited by AD people will know JE paid her off and believe G was complicate absent a credible denial. Now it is reported that G engaged in direct abuse - as I feared would happen. Next reports to the authorities will be made. It is necessary from a litigation, investigatory and reputational reason to issue a cogent denial. I can see why JE doesn't want this as it may not suit him but he is already toast. Philip Sent from my iPhone Had Geordie on the phone half a dozen times today. He would have give us a better hearing than most I figure. Strongly believe saying nothing is the wrong thing - especially as Dershowitz has a big piece coming in The Times on Monday. PRIVILEGED GM_00"1055 GM_01069 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1330-22 Filed 01/05/24 Page 3 of 22 Rest up and speak Monday Best Ross Sent from my BlackBerry® wireless device From: Philip Barden Date: Sat, 10 Jan 2015 18:27:12 +0000 To: G Maxwell<GMax l @ellmax.com<mailto:GMax [email protected]>> Cc: Ross Go Subject: Re: All I am back on line now. I see the statement didn't go. Monday? Maybe tomorrow? I will speak to Jeffery Epstein's lawyer but JE has a conflict with you and will want your silence as whilst you are being attacked there is less heat on him. Either Virginia Roberts is lying or not. If we let her lie without challenge then the lies become the reality and that may lead to you facing investigation. These are serious allegations and In the UK prosecuting people who face allegations of sex abuse is now common place and a lot of resources are focused on this. We can't sit back and let you be a conspirator by silence. Your are not guilty and must follow Dershowtiz line. He is a leading lawyer and he hasn't followed the don't say anything for fear of litigation. He has rightly called YR bluff and shouted his innocence. You have to stand up and deny the allegations or be branded guilty by association and that may lead to other investigations and worse. I feel I am going around in circles. I know what is right to do and that is to shout your innocence. Try and get some rest. Call me tomorrow if you want anytime. Speak to Deshowitz. Don't allay yourself to JE as that is not the way to go. Best Philip Sent from my iPhone 2 PRIVILEGED GM 001056 GM_01070 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1330-22 Filed 01/05/24 Page 4 of 22 On 10 Jan 2015, at 16:02, "G Maxwell" <GMax [email protected]<mailto:GMax [email protected]><mailto:GMax [email protected]>> wrote: I am out of my depth to understanding defamation and other legal hazards and don't want to end up in a law suit aimed at me from anyone if I can help it. Apparently even saying Virginia is a lier has hazard! I have never been in a suit criminal or civil and want it to stay that way. The US lawyers for the Jane Does are filling additional discovery motions and if I speak I open my self to being part of discovery apparently. I am trying to stay out of litigation and not have to employ lawyers for years as I get lost in US legal nightmare. I stand no legal risk currently on these old charges and civil suits against Jeffrey We need to consult with US lawyers on any statement I make and the complaints too Perhaps we make a statement of the legal risk of saying anything for potential defamation or something that prevents a full and frank detailed rebuttal + the press not being the place for that? Regardless, Philip plse call jeffrey lawyer and see what you can understand from him and pehaps craft something in conjunction with him? Either way I think you need to speak to him to understand my risk so you can help me understand it - too may cooks in the kitchen and I can't make good decisions. Plse reach out to him today + I have already suffered such a terrible and painful loss over the last few days that I can't even see what life after press he'll even looks like - statements that don't address all just lead to more questions .. what is my relationship to clinton ? Andrew on and on. Let's rest till monday. 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Please consider the environment before printing this email. 4 PRIVILEGED GM 001058 GM_01072 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1330-22 Filed 01/05/24 Page 6 of 22 From: jeffrey E. <[email protected] > Sent: Sunday, January 11, 2015 3:27 PM To: Gmax what did you decide to do? please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved PRIVILEGED GM_001062 GM_01075 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1330-22 Filed 01/05/24 Page 7 of 22 From: jeffrey E. <[email protected]> Sent: Wednesday, January 21, 2015 4:16 PM To: Gmax Ask press to investigate whether Clinton was ever there . Challenge the press please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved 1 PRIVILEGED GM 001084 GM_01084 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1330-22 Filed 01/05/24 Page 8 of 22 From: jeffrey E. <jeevacation @gmail.com > Sent: Wednesday, January 21, 2015 12:01 PM To: Gmax Since JE was charged in 2007 for solicitation of a prostitute I have been the target of outright lies, innuendo, slander, defamation and salacious gossip and harrasment; headlines made up of quotes I have never given, statements I have never made, trips with people to places I have never been, holidays with people I have never met, false allegations of impropriety and offensive behavior that I abhor and have never ever been party to, witness to events that I have never seen, living off trust funds that I have never ever had, party to stories that have changed materially both in time place and event depending on what paper you read, and the list goes on. I have never been a party in any criminal action pertaining to JE For the record: At the time of Jeffrey's plea I was in a very long-term committed relationship with another man and no longer working with Jeffrey. Whilst I remained on friendly terms with him up until his plea, , I have had limited contact since Every story in the press innuendo and comment has been taken from civil depositions against JE, which were settled many years ago. None of the depositions were ever subject to cross examination, not one. any PRIVILEGED GM 001085 GM_01085 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1330-22 Filed 01/05/24 Page 9 of 22 standard of truth and were used for those who claimed they were victims to receive financial payment to be shared between them and their lawyers. One firm created and sold fake cases against Mr. Epstein - the firm subsequently imploded and the Rothstein, the owner of the firm was sent to jail for 50 years for his crime. The lawyer who is currently representing Virgina was his partner. need I say morel These so called 'new revelations' stem from an alleged diary from VR that reads like the memoirs she is purporting to be selling. Also perhaps pertinent - in a previous complaint against others, her claims were rejected by the police "due to .. VR .. lack of credibility " The new interest in this old settled case results from lawyers representing some of JE victims filed a suit against the US government not JE . They contend that the Us govt violated their rights. The document and deal that JE negotiated with the government was given to the lawyers 6 years ago and is a public document. I am not part of, nor did you have anything to do with, JE plea bargain I have never even seen the proceedings nor any of the depositions 2 PRIVILEGED GM_001086 GM_01086 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1330-22 Filed 01/05/24 Page 10 of 22 I reserve my right to file complaint and sue for defamation and slander please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved 3 PRIVILEGED GM 00'1087 GM_01087 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1330-22 Filed 01/05/24 Page 11 of 22 From: jeffrey E. <[email protected] > Sent: Wednesday, January 21, 2015 4:47 PM To: G Maxwell Subject: Re: FW: Guardian This will now end but I think a dismissive statement is ok On Wednesday, January 21, 2015 , G Maxwell <[email protected]> wrote: See bellow THE TERRAMAR PROJECT FACEBOOK TWITTER G+ PINTEREST INSTAGRAM PLEDGE THE DAILY CATCH From: Ross Gow Date: Wednesday, January 21, 2015 at 17:45 PM To: Phi li p Barden, gmax Subject: Fwd: Guardian So this isn't getting better ... latest from our chums at The Guardian. ---------- Forwarded message---------- From: Jon Swaine Date: Wednesday, January 21, 2015 Subject: Guardian To: Ross As discussed - here is the new affidavit from Virginia Roberts . She claims to have had sex with Ms Maxwell when Roberts was 15 years old. She alleges that Ms Maxwell was "heavily involved in the illegal sex" and "she had sex with underage girls virtually every day when I was around her". Roberts also says that Ms Maxwell "had large amounts of child pornography that she personally made". Please do pass on any comment or response Ms Maxwell would like to make. PRIVILEGED GM 001088 GM_01088 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1330-22 Filed 01/05/24 Page 12 of 22 Thanks and all best Jon Visit theguardian .com . On your mobile and tablet, download the Guardian iPhone and Android apps theguardian .com/guardianapp and our tablet editions theguardian .com/editions. Save up to 57% by subscribing to the Guardian and Observer - choose the papers you want and get full digital access. Visit subscribe.theguardian .com This e-mail and all attachments are confidential and may also be privileged . If you are not the named recipient, please notify the sender and delete the e-mail and all attachments immediately . Do not disclose the contents to another person . You may not use the information for any purpose, or store, or copy, it in any way . Guardian News & Media Limited is not liable for any computer viruses or other material transmitted with or as part of this e-mail. You should employ virus checki ng software. Guardian News & Media Limited is a member of Guardian Media Group pie. Registered Office: PO Box 68164, Kings Place, 90 York Way , London , N1 P 2AP. Registered in England Number 908396 Ross Gow Managing Partner ACUITY Reputation 23 Berkeley Squa re London WlJ 6HE www.acuityreputation.com The information contained in this e-mail and any attachments is confidential and may be privileged or otherwise protected from disclosure. It is intended solely for the attention and use of the named addressee(s). If you are not the intended recipient, dissemination, copying or use of this e-mail and any attachments in whole or in part is prohibited . If you have received the e-mail in error, please notify the sender and delete the e-mail and any attachments from your computer system. Whilst any attachments may have been checked for viruses, you should rely on your own virus checker and procedures. No responsibil ity is accepted by ACUITY Reputation Limited for loss or damage arising from the receipt or use of th is e-mail. 2 PRIVI LEGED GM_001089 GM_01089 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1330-22 Filed 01/05/24 Page 13 of 22 please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved 3 PRIVILEGED GM 001090 GM_01090 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1330-22 Filed 01/05/24 Page 14 of 22 From: jeffrey E. <[email protected]> Sent: Thursday, January 22, 2015 12:44 PM To: Gmax ive tried to call. what have you decided? please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved PRIVILEGED GM 001091 GM_01091 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1330-22 Filed 01/05/24 Page 15 of 22 From: jeffrey E. <[email protected] > Sent: Friday, January 23, 2015 4:46 PM To: G Maxwell Subject: Re: FW: Hi should not be legal. On Fri, Jan 23, 2015 at 6:03 PM, G Maxwell <[email protected]> wrote: gawker have printed the entire address book, albeit redacted x Sent from my iPad please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved PRIVILEGED GM_001092 GM_01092 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1330-22 Filed 01/05/24 Page 16 of 22 From: jeffrey E. <[email protected]> Sent: Friday, January 23, 2015 6:40 PM To: G Maxwell Subject: Re: Hi I am convinced your statement should be be about the clinton story being easily dsiporived. On Fri, Jan 23, 2015 at 8:07 PM, G Maxwell <GM ax l @ellmax.com> wrote: My friends are apoplectic .. Do you know what edwards et al want from all this shit? What are they looking for? What is the end game? THE TERRAMAR PROJECT FACEBOOK TWITTER G+ PINTEREST INSTAGRAM PLEDGE THE DAILY CATCH From: jeffrey E. Sent: Friday, 23 January 2015 18:46 To: G Maxwell Subject: Re: FW: Hi should not be legal. On Fri, Jan 23, 2015 at 6:03 PM, G Maxwell <GMax [email protected]> wrote: gawker have printed the entire address book, albeit redacted x Sent from my iPad please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by 1 PRIVILEGED GM_001093 GM_01093 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1330-22 Filed 01/05/24 Page 17 of 22 return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved 2 PRIVILEGED GM __ 001094 GM_01094 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1330-22 Filed 01/05/24 Page 18 of 22 From: jeffrey E. <[email protected]> Sent: Friday, January 23, 2015 6:14 PM To: G Maxwell Subject: Re: Hi publiclity On Fri, Jan 23, 2015 at 8:07 PM, G Maxwell <[email protected]> wrote: My friends are apoplectic .. Do you know what edwards et al want from all this shit? What are they looking for? What is the end game? THE TERRAMAR PROJECT FACEBOOK TWITTER G+ PINTEREST INSTAGRAM PLEDGE THE DAILY CATCH From: jeffrey E. Sent: Friday, 23 January 2015 18:46 To: G Maxwell Subject: Re: FW: Hi should not be legal. On Fri, Jan 23, 2015 at 6:03 PM, G Maxwell <[email protected]> wrote: gawker have printed the entire address book, albeit redacted x Sent from my iPad please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by 1 PRIVILEGED GM 001095 GM_01095 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1330-22 Filed 01/05/24 Page 19 of 22 return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved 2 r.)RIVILEGED GM __ 001096 GM_01096 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1330-22 Filed 01/05/24 Page 20 of 22 From: jeffrey E. <[email protected] > Sent: Sunday, January 25, 2015 4:30 PM To: G Maxwell Subject: Re: Update - FYI thnaks On Sun, Jan 25, 2015 at 7:27 PM, G Maxwell <GMaxI @ellmax.com> wrote: All had quietened down over here in last 24 hours but just googled you all again and under JE the daily mail printed a story 6 hours ago that they picked up from the daily beast which is jane doe l's testimony (and video interview) about how Haley robson recruited her to give je one massage when she was 14 and goes into detail about what happened - Sent from my iPad please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved PRIVILEGED GM __ 001097 GM_01097 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1330-22 Filed 01/05/24 Page 21 of 22 From: jeffrey E. <[email protected]> Sent: Sunday, January 25, 2015 4:41 AM To: G Maxwell Subject: Re: ok, with me, You have done nothing wrong and i woudl urge you to start acting like it. go outside, head high, not as an esacping convict. go to parties. deal with it. . i had Iisa svenson the swedish ocean ambassador yesteady she said no one on her ocean panel takes this stuff seriously and you would be welcoe to the ocean conferenec water conference etc. On Sat, Jan 24, 2015 at 1:22 PM, G Maxwell <[email protected]> wrote: I would appreciate it i f - would come out and say she was your g'friend - I think she was from end 99 to 2002 THE TERRAMAR PROJECT FACEBOOK TWITTER G+ PINTEREST INST AGRAM PLEDGE THE DAILY CATCH please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved 1 PRIVILEG ED GM 001098 GM_01098 CONFIDENTIAL  Case 1:15-cv-07433-LAP Document 1330-22 Filed 01/05/24 Page 22 of 22 From: G Maxwell <[email protected]> Sent: Tuesday, January 27, 2015 10:36 AM To: jeffrey E. Subject: Re: I have not decided what to do THE TERRAMAR PROJECT FACEBOOK TWITTER G+ PINTEREST INSTAGRAM PLEDGE THE DAILY CATCH From: jeffrey E. Sent: Tuesday, 27 January 2015 11:50 To: G Maxwell Subject: what has happned to you and your statmenet?? please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved PRIVILEGED GM 001099 GM_01099 CONFIDENTIAL