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Case 1:15-cv-07433-RWS Document 539 Filed 01/06/17 Page 1 of 7
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
VIRGINIA L. GIUFFRE,
v.
Plaintiff,
15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X
Declaration of Laura A. Menninger in Support of
Defendant’s Motion For Summary Judgment
I, Laura A. Menninger, declare as follows:
1. I am an attorney at law duly licensed in the State of New York and admitted to
practice in the United States District Court for the Southern District of New York. I am a
member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant
Ghislaine Maxwell in this action. I respectfully submit this Declaration in support of
Ms. Maxwell’s Motion for Summary Judgment. 1
2. Attached as Exhibit A is a true and correct copy of an article by Sharon Churcher
entitled “Prince Andrew and the 17-year-old girl his sex offender flew to Britain to meet him,”
DAILY MAIL, dated March 2, 2011.
1
At trial, defendant intends to produce either the custodian of record relevant to any
disputed document or a certification in compliance with either Fed. R. Evid. P. 803 and/or 902.
See Fed. R. Civ. P. 56(c). Apart from deposition testimony, the majority of non-deposition
documents herein were either produced by plaintiff or obtained with releases signed by plaintiff.
Case 1:15-cv-07433-RWS Document 539 Filed 01/06/17 Page 2 of 7
3. Attached as Exhibit B is a true and correct copy of an article by Sharon Churcher
entitled “Teenage girl recruited by paedophile Jeffrey Epstein reveals how she twice met Bill
Clinton,” DAILY MAIL, dated March 5, 2011.
4. Attached as Exhibit C is a true and correct copy of a statement on behalf of Ms.
Maxwell dated March 9, 2011.
5. Attached as Exhibit D (filed under seal)
6. Attached as Exhibit E is a true and correct copy of an Order Denying Motion to Join
Under Rule 21, Doe v. United States, No. 08-80736-Civ-Marra/Johnson (S.D. Fla. Apr. 7, 2016).
7. Attached as Exhibit F is a true and correct copy of a statement on behalf of Ms.
Maxwell dated January 2, 2015.
8. Attached as Exhibit G (filed under seal)
9. Attached as Exhibit H (filed under seal)
10. Attached as Exhibit I (filed under seal)
2
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11. Attached as Exhibit J (filed under seal)
12. Attached as Exhibit K (filed under seal)
13. Attached as Exhibit L (filed under seal)
14. Attached as Exhibit M (filed under seal)
15. Attached as Exhibit N (filed under seal)
16. Attached as Exhibit O (filed under seal)
17. Attached as Exhibit P (filed under seal)
18. Attached as Exhibit Q (filed under seal)
3
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19. Attached as Exhibit R (filed under seal)
20. Attached as Exhibit S (filed under seal)
21. Attached as Exhibit T (filed under seal)
22. Attached as Exhibit U (filed under seal)
23. Attached as Exhibit V (filed under seal)
24. Attached as Exhibit W (filed under seal)
25. Attached as Exhibit X(filed under seal)
26. Attached as Exhibit Y (filed under seal)
27. Attached as Exhibit Z (filed under seal)
4
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28. Attached as Exhibit AA (filed under seal)
29. Attached as Exhibit BB (filed under seal)
30. Attached as Exhibit CC (filed under seal)
31. Exhibit DD left intentionally blank.
32. Attached as Exhibit EE (filed under seal)
33. Attached as Exhibit FF (filed under seal)
34. Attached as Exhibit GG (filed under seal)
35. Attached as Exhibit HH (filed under seal)
36. Attached as Exhibit II (filed under seal)
5
Case 1:15-cv-07433-RWS Document 539 Filed 01/06/17 Page 6 of 7
37. Attached as Exhibit JJ (filed under seal)
38. Attached as Exhibit KK (filed under seal)
.
39. Attached as Exhibit LL is a true and correct copy of the Victims Refuse Silence, Inc.
Articles of Incorporation dated December 23, 2014, GIUFFRE001064-5.
40. Attached as Exhibit MM (filed under seal)
I declare under penalty of perjury that the foregoing is true and correct.
Executed on January 6, 2017.
s/ Laura A. Menninger
Laura A. Menninger
6
Case 1:15-cv-07433-RWS Document 539 Filed 01/06/17 Page 7 of 7
CERTIFICATE OF SERVICE
I certify that on January 6, 2017, I electronically served this Declaration of Laura A. Menninger
in Support of Defendant’s Motion for Summary Judgment via ECF on the following:
Sigrid S. McCawley
Meredith Schultz
BOIES, SCHILLER & FLEXNER, LLP
401 East Las Olas Boulevard, Ste. 1200
Ft. Lauderdale, FL 33301
smccawley@bsfllp.com
mschultz@bsfllp.com
Bradley J. Edwards
FARMER, JAFFE, WEISSING, EDWARDS,
FISTOS & LEHRMAN, P.L.
425 North Andrews Ave., Ste. 2
Ft. Lauderdale, FL 33301
brad@pathtojustice.com
Paul G. Cassell
383 S. University Street
Salt Lake City, UT 84112
cassellp@law.utah.edu
J. Stanley Pottinger
49 Twin Lakes Rd.
South Salem, NY 10590
StanPottinger@aol.com
/s/ Nicole Simmons
Nicole Simmons
7
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EXHIBIT B
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EXHIBIT C
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Statement on Behalf of Ghislaine
Maxwell
i FL)NES D;,' e- MARC t I,). 20:: 1
LONDON, March 10, 2011 - Ghislaine Maxwell denies the
various allegations about her
that have appeared recently in the media. These allegations
are all entirely
false.
Older News
S M T W T F S
20 2122 23 24 25 26
2728 1 2 3 4 5
6 7 8 9 10 11 12
It is unacceptable that letters sent by Ms Maxwell' s legal
representatives to certain newspapers pointing out the truth
and asking for
the allegations to be withdrawn have simply been ignored.
In the circumstances, Ms Maxwell is now proceeding to take
legal action against those newspapers.
I understand newspapers need stories to sell copies. It is
well known that certain newspapers live by the adage, " why
let the truth get
in the way of a good story." However, the allegations made
against me are
abhorrent and entirely untrue and I ask that they stop," said
Ghislaine
Maxwell
A number of newspapers have shown a complete lack of
accuracy
in their reporting of this story and a failure to carry out the
most
elementary investigation or any real due diligence. I am now
taking action to
clear my name," she said.
Media
contact:
Ross
Cow
Acuity Reputation
Tel: + 44- 203- 008- 7790
Mob: + 44- 7778- 755- 251
Email: ross@acuityreputation. com
Media contact: Ross Gow, Acuity Reputation, Tel: + 44-203-
oo8-7790, Mob: + 44-7778- 755- 251, Email: ross at
acu ityreputation, com
iled.under: Government and Policy, Law, Media
Tags: Devonshves Solicitors, Landon, March io, United Kingdom
GOVERNMENT AND POLICY MARCH 10
NEONS -
NEWS
CSA Group Selects Frankfurt, Germany for -
new European Headquarters
The First International Gateway to Africa
Conference in Geneva: Africa& apos;s
Challenges Today and Tomorrow
Central Saint Martins and Method Launch
Accelerator to Drive Innovation and Support
UK Economic Growth _.. _... _.
North East Lincolnshire Council
Emplovees& apos; Ideas Win Votes
Teel, Mahindra Opens a
new Development
Centre in Bonn,
Germany
website Optimisation
and
Marketing
FromFrom Ztieblina
Sir Paul McCartney
Supports BUAV
Campaign to end Cruel
7
AGREN BIANDO REPORTING
5-13 //61 9H
GIUFFREOO1067
Case 1:15-cv-07433-RWS Document 539-4 Filed 01/06/17 Page 1 of 1
REDACTED
EXHIBIT D
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EXHIBIT E
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Case 9: 05- cv- 60736- SCAM Document 324 Entered on FLSD Docket 04/ 07/ 2015 Page 1 of 10
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.. 08- CV- 80736- KAM
JANE DOE 1 and JANE DOE 2,
Petitioners,
UNITED STATES OF AMERICA,
Respondent.
ORDER DENYING PETITIONERS' MOTION TO JOIN UNDER RULE 21 AND
MOTION TO AMEND UNDER RULE 15
This cause is before the Court on Jane Doe 3 and Jane Doe 4' s Corrected Motion
Pursuant to Rule 21 for Joinder in Action (" Rule 21 Motion") ( DE 280), and Jane Doe 1
and Jane
Doe 2' s Protective Motion Pursuant to Rule 15 to Amend Their Pleadings to Conform to
Existing Evidence and to Add Jane Doe 3 and Jane Doe 4 as Petitioners ("
Rule 15 Motion") ( DE
311). Both motions are ripe for review. For the following reasons, the Court concludes that they
should be denied.
I. Background
This is an action by two unnamed petitioners, Jane Doe 1
and Jane Doe 2, seeking to
prosecute a claim under the Crime Victims' Rights Act (CVRA), 18 U.S. C. § 3771. ( DE 1).
Generally, they allege that the respondent Government violated their rights under the CVRA by
failing to consult with them before negotiating a non -prosecution agreement with Jeffrey Epstein,
who subjected them to various sexual crimes while they were minors. (
Id.). Petitioners initiated
this action in July 2008. ( Id.).
GIUFFRE002844
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On December 30, 2014, two other unnamed victims, Jane Doe 3 and Jane Doe 4, moved
to join as petitioners in this action pursuant to Federal Rule of Civil Procedure 21. ( DE 280).
Petitioners ( Jane Doe 1 and Jane Doe 2) support the Rule 21 Motion. ( Id. at 11). Jane Doe 3 and
Jane Doe 4 argue that they " have suffered the same violations of their rights under the [ CVRA]
as the" Petitioners, and they " desire to join in this action to vindicate their rights as well." (
Id. at
1). The Government vehemently opposes joinder under Rule 21. ( DE 290). The Government
argues that Rule 15 is the proper procedural device for adding parties to an action, not Rule 21.
at 1).
O] ut of an abundance of caution," Petitioners filed a motion to amend their petition
under Rule 15, conforming the petition to the evidence and adding Jane Doe 3 and Jane Doe 4 as
petitioners. ( DE 311 at 2). The Government opposes the Rule 15 Motion as well. ( DE 314).
Among other things, the Government argues that amending the petition to include Jane Doe 3
and Jane Doe 4 should be denied because of their undue delay in seeking to join the proceedings,
and the undue prejudice that amendment will cause. ( Id.).
After considering the parties' submissions and the proposed amended petition, the Court
finds that justice does not require amendment in this instance and exercises its discretion to deny
the amendment.
II. Discussion
The decision whether to grant leave to amend a complaint is within the sole discretion of
the district court." Laurie v. Ala. Ct. Crim. Apps., 256 F. 3d 1266, 1274 ( 11th Cir. 2001). "
The
court should freely give leave when justice so requires." Fed. R. Civ. P. 15( a)( 2). Justice does
not require amendment in several instances, " includ[ ing] undue delay, bad faith, dilatory motive
N
GIUFFRE002845
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on the part of the movant....
undue prejudice to the opposing parry by virtue of allowance of the
amendment, [ and] futility of amendment."' Laurie, 256 F. 3d at 1274 ( quoting Foman v. Davis,
371 U. S. 178, 182 ( 1962)). In addition to considering the effect of amendment on the parties, the
court must consider " the importance of the amendment on the proper determination of the merits
of a dispute." 6 Wright & Miller, Fed. Prac. & Fed. P. § 1488, p. 814 ( 3d ed. 2010). Justice does
not require amendment where the addition of parties with duplicative claims will not materially
advance the resolution of the litigation on the merits. See Herring v. Delta Air Lines, Inc., 894
F. 2d 1020, 1024 ( 9th Cir. 1989).
A. Rule 21 Motion
Jane Doe 3 and Jane Doe 4' s first attempt to join in this proceeding was brought under
Rule 21. ( DE 280). " If parties seek to add a party under Rule 21, courts generally use the
standard of Rule 15, governing amendments to pleadings, to determine whether to allow the
addition." 12 Wright & Miller, Fed. Prac. & Fed. P., p. 432 ( 3d ed. 2013);
see also Galustian v.
Peter, 591 F. 3d 724, 729- 30 ( 4th Cir. 2010) ( collecting cases and noting that Rule 15( a) applies
to amendments seeking to add parties);
Frank v. U.S. West, Inc., 3 F. 3d 1357, 1365 ( 10th Cir.
1993) (" A motion to add a parry is governed by Fed. R. Civ. P. 15( a) ....")
Rule 21, " Misjoinder and Nonjoinder of Parties," provides the court with a tool for
correcting the " misjoinder" of parties that would otherwise result in dismissal. Fed. R. Civ. P.
21. Insofar as Rule 21 " relates to the addition of parties, it is intended to permit the bringing in
of a person, who through inadvertence, mistake or for some other reason, had not been made a
parry and whose presence as a parry is later found necessary or desirable." United States v. Com.
Bank of N. Am., 31 F. R.D. 133, 135 ( S. D.N.Y. 1962) ( internal quotation marks omitted).
3
GIUFFRE002846
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In their Rule 21 Motion, Jane Doe 3 and Jane Doe 4 do not claim that they were omitted
from this proceeding due to any " inadvertence" or " mistake" by Petitioners; rather, they seek to
join this proceeding as parties that could have been permissively joined in the original petition
under Rule 20 (" Permissive Joinder of Parties"). As courts generally use the standards of Rule
15 to evaluate such circumstances, the Court will consider the joinder issue as presented in the
Rule 15 Motion. The Court will consider the arguments presented in the Rule 21 Motion as if
they are set forth in the Rule 15 Motion as well. Because the arguments are presented in the Rule
15 Motion (and because the Court is denying the Rule 15 Motion on its merits, as discussed
below), the Rule 21 Motion will be denied.
The Court also concludes that portions of the Rule 21 Motion
and related
filings
should be stricken from the record. Pending for this Court' s consideration is a Motion
for Limited Intervention filed by Alan M. Dershowitz, who seeks to intervene to " strike the
outrageous and impertinent allegations made against him and [ to] request[] a show cause order to
the attorneys that have made them." ( DE 282 at 1).
The Court has considered Mr. Dershowitz' s
arguments, but it finds that his intervention is unnecessary as Federal Rule of Civil Procedure
12(f) empowers the Court " on its own" to " strike from a pleading an insufficient defense or any
redundant, immaterial, impertinent, or scandalous matter." Fed. R. Civ. P. 12(f).
Petitioners' Rule 21 Motion consists of relatively little argumentation regarding why the
Court should permit them to join in this action. they argue that ( 1)
they were sexually abused by
The Court notes that, regardless of which motion it considers, the same standard
governs the addition of parties under Rule 21 and Rule 15. See Goston v. Potter, No. 08- cv- 478
FJS ATB, 2010 WL 4774238, at * 5 ( N.D.N.Y. 2010) ( citing Bridgeport Music, Inc. v. Universal
Music Grp., Inc., 248 F.R.D. 408, 412 ( S. D.N.Y. 2008)).
M
GIUFFRE002847
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Jeffrey Epstein, and ( 2) the Government violated their CVRA rights by concealing the non-
prosecution agreement with them. ( DE 280 at 3; see id. at 7- 8).
However, the bulk of the Rule
21 Motion consists of copious factual details that Jane Doe 3 and Jane Doe 4 " would prove" "[ i]f
allowed to join this action." ( Id. at 3, 7). Specifically, Jane Doe 3 proffers that she could prove
the circumstances under which a non -parry introduced her to Mr. Epstein, and how Mr. Epstein
sexually trafficked her to several high- profile non -parry individuals, " including numerous
prominent American politicians, powerful business executives, foreign presidents, a well- known
Prime Minister, and other world leaders." ( Id. at 3- 6). She names several individuals, and she
offers details about the type of sex acts performed and where they took place. See id. at 5)?
At this juncture in the proceedings, these lurid details are unnecessary to the
determination of whether Jane Doe 3 and Jane Doe 4 should be permitted to join Petitioners'
claim that the Government violated their rights under the CVRA. The factual details regarding
with whom and where the Jane Does engaged in sexual activities are immaterial and impertinent
to this central claim ( i.e., that they were known victims of Mr. Epstein and the Government owed
them CVRA duties), especially considering that these details involve non-parties who are not
related to the respondent Government. These unnecessary details shall be stricken.
The original Rule 21 Motion (DE 279) shall be stricken in its entirety, as it is wholly
superseded by the " corrected" version of the Rule 21 Motion (DE 280).
From the corrected Rule
21 Motion, the Court shall strike all factual details regarding Jane Doe 3 between the following
sentences: " The Government then concealed from Jane Doe 43 the existence of its NPA from
z
280 at 7- 8).
Jane Doe 4' s proffer is limited to sexual acts between Mr. Epstein and herself. ( See DE
GIUFFRE002848
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Jane Doe 43, in violation of her rights under the CVRA" (id. at 3); and " The Government was
well aware of Jane Doe 43 when it was negotiating the NPA, as it listed her as a victim in the
attachment to the NPA" ( id. at 6). As none of Jane Doe 4' s factual details relate to non-parties,
the Court finds it unnecessary to strike the portion of the Rule 21 Motion related to her
circumstances. Regarding the Declaration in support of Petitioners' response to Mr.
Dershowitz' s motion to intervene (DE 291- 1), the Court shall strike paragraphs 4, 5, 7, 11, 13,
15, 19 through 53, and 59, as they contain impertinent details regarding non-parties. Regarding
the Declaration of Jane Doe 3 in support of the Rule 21 Motion (DE 310- 1),
the Court shall strike
paragraphs 7 through 12, 16, 39, and 49, as they contain impertinent details regarding non-
parties. Jane Doe 3 is free to reassert these factual details through proper evidentiary proof,
should Petitioners demonstrate a good faith basis for believing that such details are pertinent to a
matter presented for the Court' s consideration.
As mentioned, Mr. Dershowitz moves to intervene " for the limited purposes of moving to
strike the outrageous and impertinent allegations made against him and requesting a show cause
order to the attorneys that have made them." ( DE 282 at 1).
As the Court has taken it upon itself
to strike the impertinent factual details from the Rule 21 Motion and related filings, the Court
concludes that Mr. Derschowitz' s intervention in this case is unnecessary. Accordingly, his
motion to intervene will be denied as moot. 3
Regarding whether a show cause order should
3 This also moots Mr. Dershowitz' s Motion for Leave to File Supplemental Reply in
Support of Motion for Limited Intervention. ( DE 317). Denying Mr. Dershowitz' s motion to
intervene also renders moot Petitioners' motion (DE 292) to file a sealed document supporting its
response to Mr. Dershowitz' s motion. It will accordingly be denied as moot, and DE 293 ( the
sealed response) will be stricken from the record.
on
GIUFFRE002849
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issue, the Court finds that its action of striking the lurid details from Petitioners' submissions is
sanction enough. However, the Court cautions that all counsel are subject to Rule 11' s mandate
that all submissions be presented for a proper purpose and factual contentions have evidentiary
support, Fed. R. Civ. P. 11( b)( 1)
and ( 3), and that the Court may, on its own, strike from any
pleading " any redundant, immaterial, impertinent, or scandalous matter,"
Fed. R. Civ. P. 12(f).
B. Rule 15 Motion
Between their two motions ( the Rule 21 Motion and Rule 15 Motion), Jane Doe 3 and
Jane Doe 4 assert that " they desire to join in this action to vindicate their rights [ under the
CVRA] as well." ( DE 280 at 1).
Although Petitioners already seek the invalidation of Mr.
Epstein' s non -prosecution agreement on behalf of all " other similarly -situated victims" (
DE 189
at 1;
DE 311 at 2, 12, 15, 18- 19), Jane Doe 3 and Jane Doe 4 argue that they should be fellow
travelers in this pursuit, lest they " be forced to file a separate suit raising their claims" resulting
in " duplicative litigation" ( DE 280 at 11).
The Court finds that justice does not require adding
new parties this late in the proceedings who will raise claims that are admittedly " duplicative" of
the claims already presented by Petitioners.
The Does' submissions demonstrate that it is entirely unnecessary for Jane Doe 3 and
Jane Doe 4 to proceed as parties in this action, rather than as fact witnesses available to offer
relevant, admissible, and non -cumulative testimony.
See e. g., DE 280 at 2 ( Jane Doe 3 and
Jane Doe 4 " are in many respects similarly situated to the current victims"),
9 (" The new victims
will establish at trial that the Government violated their CVRA rights in the same way as it
violated the rights of the other victims."), 10 ( Jane Doe 3 and Jane Doe 4 " will simply join in
motions that the current victims were going to file in any event."), 11 ( litigating Jane Doe 3 and
7
GIUFFRE002850
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Jane Doe 4' s claims would be " duplicative"); DE 298 at 1 n. I (" As promised ... Jane Doe No. 3
and Jane Doe No. 4 do not seek to expand the number of pleadings filed in this case. If allowed
to join this action, they would simply support the pleadings already being filed by Jane Doe No. 1
and Jane Doe No. 2."); DE 311 at 5 n. 3 ("[
A] II four victims (represented by the same legal
counsel) intend to coordinate efforts and avoid duplicative pleadings."), 15 ( Jane Doe 3 and Jane
Doe 4 " challenge the same secret agreement
i.e., the NPA that the Government executed with
Epstein and then concealed from the victims. This is made clear by the proposed amendment
itself, in which all four victims simply allege the same general facts.")).
As the Does argue at
length in their Rule 15 Motion, Jane Doe 1'
s original petition " specifically allege[ s] that the
Government was violating not only her rights but the rights of other similarly -situated victims."
DE 311 at 2). The Court fails to see why the addition of "other similarly -situated victims" is
now necessary to " vindicate their rights as well." (
DE 280 at 1).
Of course, Jane Doe 3 and Jane Doe 4 can participate in this litigated effort to vindicate
the rights of similarly situated victims
there is no requirement that the evidentiary proof
submitted in this case come only from the named parties. Petitioners point out as much, noting
that, regardless of whether this Court grants the Rule 15 Motion, "they will call Jane Doe No. 3
as a witness at any trial." ( DE 311 at 17 n.7). The necessary " participation" of Jane Doe 3 and
Jane Doe 4 in this case can be satisfied by offering their properly supported
and relevant,
admissible, and non -cumulative
testimony as needed, whether through testimony at trial
see DE 280 at 9) or affidavits submitted to support the relevancy of discovery requests4
see
310- 1).
The non -parry Jane Does clearly understand how to submit affidavits. See DEs 291- 1,
GIUFFRE002851
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id. at 10). Petitioners do not contend that Jane Doe 3 and Jane Doe 4' s " participation in this
case" can only be achieved by listing them as parties.
As it stands under the original petition, the merits of this case will be decided based on a
determination of whether the Government violated the rights of Jane Doe 1,
Jane Doe 2, and all
other similarly situated victims" under the CVRA. Jane Doe 3 and Jane Doe 4 may offer
relevant, admissible, and non -cumulative evidence that advances that determination, but their
participation as listed parties is not necessary in that regard. See Herring, 894 F. 2d at 1024
District court did not abuse its discretion by denying amendment where " addition of more
plaintiffs ... would not have affected the issues underlying the grant of summary judgment.");
c£
Arthur v. Stern, 2008 WL 2620116, at * 7 ( S. D. Tex. 2008) ( Under Rule 15, " courts have held
that leave to amend to assert a claim already at issue in [ another lawsuit] should not be granted if
the same parties are involved, the same substantive claim is raised, and the same relief is
sought.")'
And, as to Jane Doe 4 at least, adding her as aparty raises unnecessary questions
about whether she is a proper party to this action.6
Petitioners also admit that amending the petition to conform to the evidence
by
including references to the non -prosecution agreement itself
is " unnecessary" as the " existing
petition is broad enough to cover the developing evidence in this case." (
DE 311). The Court
The Court expresses no opinion at this time whether any of the attestations made by
Jane Doe 3 and Jane Doe 4 in support of their motion will be relevant, admissible, and non-
cumulative.
6 The Government contends that Jane Doe 4 is not a true " victim" in this case because
she was not known at the time the Government negotiated the non -prosecution agreement, and
accordingly she was not entitled to notification rights under the CVRA. See DE 290 at 10).
Any " duplicative" litigation filed by Jane Doe 4 would necessarily raise the issue of whether she
has standing under the CVRA under these circumstances.
M
GIUFFRE002852
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agrees, and it concludes that justice does not require amending the petition this late in the
proceedings.
III. Conclusion
Accordingly, it is hereby ORDERED AND ADJUDGED as follows: the Rule 21 Motion
DE 280) is DENIED; the Rule 15 Motion ( DE 311) is DENIED; Intervenor Dershowitz' s
Motion for Limited Intervention (DE 282) and Motion for Leave to File Supplemental Reply in
Support of Motion for Limited Intervention (DE 317) are DENIED AS MOOT; Petitioners'
Motion to Seal ( DE 292) is DENIED AS MOOT; the following materials are hereby
STRICKEN from the record:
DE 279, in its entirety.
DE 280, all sentences between the following sentences:
The Government then concealed from Jane Doe 43 the
existence of its NPA from Jane Doe 43, in violation of her
rights under the CVRA" ( DE 280 at 3); and " The
Government was well aware of Jane Doe 43 when it was
negotiating the NPA, as it listed her as a victim in the
attachment to the NPA" ( DE 280 at 6).
DE 291- 1, paragraphs 4, 5, 7, 11, 13, 15, 19 through 53,
and 59.
DE 310- 1, paragraphs 7 through 12, 16, 39, and 49.
DE 293, in its entirety.
DONE AND ORDERED in chambers at West Palm Beach, Palm Beach County,
Florida, this 6' day of April, 2015.
KENNETH A. MARRA
United States District Judge
10
GIUFFRE002853
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Case 1:15-cv-07433-RWS Document 539-6 Filed 01/06/17 Page 2 of 2
From: < ross@acuityreputation.com>
Date: 2 January 2015 at 20: 38
Subject: Ghislaine Maxwell
To: Rossacuity Gow < ross@acuityreputation. com>
bcc: martin. robinson(cDmailonline. co. uk,
P. Peachev@independent. co. uk,
nick.sommerlad@mirror.co. uk,
david. brown@thetimes. co. uk,
nick.alwav@bbc.co. uk,
io- anne. Pugh@bbc. co. uk
To Whom It May Concern,
Please find attached a quotable statement on behalf of Ms Maxwell.
No further communication will be provided by her on this matter.
Thanks for your understanding.
Best
Ross
Ross Gow
ACUITY Reputation
Jane Doe 3 is Virginia Roberts - so not a new individual. The allegations made by Victoria
Roberts against Ghislaine Maxwell are untrue. The original allegations are not new and have
been fully responded to and shown to be untrue.
Each time the story is re told it changes with new salacious details about public figures and
world leaders and now it is alleged by Ms Roberts that Alan Derschowitz is involved in having
sexual relations with her. which he denies.
Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as
they are defamatory.
Ghislaine Maxwell' s original response to the lies and defamatory claims remains the same.
Maxwell strongly denies allegations of an unsavoury nature, which have appeared in the British
press and elsewhere and reserves her right to seek redress at the repetition of such old
defamatory claims.
Sent from my BlackBerry° wireless device
IEXHIBIT
E
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EXHIBITS G-KK
Case 1:15-cv-07433-RWS Document 539-8 Filed 01/06/17 Page 1 of 4
EXHIBIT LL
Case 1:15-cv-07433-RWS Document 539-8 Filed 01/06/17 Page 2 of 4
ARTICLES OF INCORPORATION
In compliance with Chapter 617, F. S., ( Not for Profit)
ARTICIS I
NAME
The name of the cQrporation shall be:
I
Victims Refuse Silence, Inc.
ARTICLE H
PRINCIPAL OFFICE
Principal street address;
425 North Andrews Ave.
Mailing address, if different is:
Suite 2
Fort Lauderdale, FL 33301
ARTICLE J7Z
PURPOSE
The purpose for which the corporation is organized is:
Victims Refuse Silence, Inc. is organized exclusively for charitable and
educational purposes including, for such purposes, the making of distributions to organizations that qualify as exempt
organizations under section 501( c)( 3) of the Internal Revenue Code, or the corresponding section of any future federal tax
code. The corporation is organized to provide assistance to victims of sexual abuse as well as victims of human trafficking.
Upon the dissolution of Victims Refuse Silence, Inc., assets shall be distributed for one or more exempt purpose within
the meaning of section 501( c)( 3) of the Internal Revenue Code, or corresponding section of any future federal tax
code, or shall be distributed to the federal government, or to a state or local government, for a public purpose.
ARTICLE IV
MANNER OF ELECTION - The manner in which the directors are elected and appointed:
The manner in
which the directors are elected or appointed is provided in the bylaws of the Corporation.
Name and Title:
Address
Virginia Roberts, Director
425 North Andrews Ave.
Suite 2
Fort Lauderdale, FL 33301
Name and Title:
Address:
F—
M
0
M
Name and Title:- Bradley J. Edwards, Director Name and
Address
425 North Andrews Ave.
Address:
Suite 2
Fort Lauderdale, FL 33301
Name and Title: Brittany N. Henderson, Director Name and
Address
425 North Andrews Ave.
Address:
Suite 2
Fort Lauderdale, FL 33301
GlUFFRE00 1063
Case 1:15-cv-07433-RWS Document 539-8 Filed 01/06/17 Page 3 of 4
Name and Title -.—
Name and Title-,
Address
Address:
Name and Title:
Name and Title:
Address
Address:
ARTICLE VT JWGISTERED AGENT
The name andFlorida street address ( P.O. Box NOT acceptable) of the registered agent is:
Name:
Address:
Bradley J. Edwards
425 North Andrews Ave., Suite 2
Fort Lauderdale, FL 33301
ARTICLE VH Z.NCQM:-ORATOR
The name and address of the Incorporator is:
Name:
Address-
Brittany N. Henderson
425 North Andrews Ave., Suite 2
Fort Lauderdale, FL 33301
Having been named as registered agent to accept service ofprocess for the above stated corporation at the place designated in this
certificate, I am.UwWar with and acceptjAe-qppWWMren1Las registered agent and agree to act in this capacity
Required 1-t-p-a-MrebtitermqVd-Agent
Date
I submit this document and affirm that thefacts stated herein are true. I am aware that any false information submitted in a document
to tfte Department ofState constitutes a third degreefelony as providedfar in s.817.155, F.S.
gnature
t2 I n I \
Date '
A
G1UFFRE00 1064
I
2015 FLORIDA NOT FOR PROFIT CORPORATION AMENDED ANNUAL FILED
REPORT
Apr 22, 2015
DOCUMENT# N14000011657
Case 1:15-cv-07433-RWS Document 539-8 Filed 01/06/17 Page 4 of 4
Entity Name: VICTIMS REFUSE SILENCE, INC.
Current Principal Place of Business:
425 NORTH ANDREWS AVE., SUITE 2
FORT LAUDERDALE, FL 33301
Secretary of State
CC7801725405
Current Mailing Address:
425 NORTH ANDREWS AVE., SUITE 2
FORT LAUDERDALE, FL 33301
FEI Number: 47- 2627774
Certificate of Status Desired: Yes
Name and Address of Current Registered Agent:
EDWARDS, BRADLEY J
425 NORTH ANDREWS AVE., SUITE 2
FORT LAUDERDALE, FL 33301 US
The above named entity submits this statement for the purpose of changing its registered office or registered agent, or both, in the State of Florida.
SIGNATURE:
Electronic Signature of Registered Agent
Date
Officer/Director Detail :
Title PRESIDENT, DIRECTOR Title VP, DIRECTOR
Name GIUFFRE, VIRGINIA L Name GARVIN, MARGARET A
Address 425 NORTH ANDREWS AVE.. SUITE 2 Address 425 NORTH ANDREWS AVE.. SUITE 2
City -State -Zip: FORT LAUDERDALE FL 33301
City -State -Zip: FORT LAUDERDALE FL 33301
Title
SECRETARY, DIRECTOR
Name HENDERSON, HENDERSON, BRITTANY BRITTANY NN
Address 425 425 NORTH NORTH ANDREWS ANDREWS AVE., AVE., SUITE SUITE 22
City -State -Zip: FORT LAUDERDALE FL 33301
hereby certify that the information indicated on this report or supplemental report is true and accurate and that my electronic signature shall have the same legal effect as if made under
oath, that I am an officer or director of the corporation or the receiver or trustee empowered to execute this report as required by Chapter 617, Florida Statutes, and that my name appears
above, or on an attachment with all other like empowered.
SIGNATURE: BRITTANY N HENDERSON DIRECTOR 04/ 22/ 2015
Electronic Signature of Signing Officer/Director Detail
Date
GIUFFRE001065
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EXHIBIT MM