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12. In light of information I received suggesting that British socialite Ghislaine Maxwell,
former girlfriend and long-time friend of Epstein's, was involved in managing Epstein's
affairs and companies I had her served for deposition for August 17, 2009. (Deposition
Notice attached to Statement of Undisputed Facts as Exhibit BB). Maxwell was
represented by Brett Jaffe of the New York firm of Cohen and Gresser, and I
understood that her attorney was paid for (directly or indirectly) by Epstein. She was
reluctant to give her deposition, and I tried to work with her attorney to take her
deposition on terms that would be acceptable to both sides. Her attorney and I
negotiated a confidentiality agreement, under which Maxwell agreed to drop any
objections to the deposition. Maxwell, however, still avoided the deposition. On June
29, 2010, one day before I was to fly to NY to take Maxwell's deposition, her attorney
informed me that Maxwell's mother was deathly ill and Maxwell was consequently
flying to England with no intention of returning and certainly would not return to the
United States before the conclusion of Jane Doe's trial period (August 6, 2010).
Despite that assertion, I later learned that Ghislaine Maxwell was in fact in the country
on approximately July 31, 2010, as she attended the wedding of Chelsea Clinton
(former President Clinton's daughter) and was captured in a photograph taken for US
Weekly magazine.
13. Epstein alleges that there was something improper in the fact that I notified him that I
intended to take Donald Trump's deposition in the civil suits against him. Trump was
properly noticed because: (a) after review of the message pads confiscated from
Epstein's home, the legal and investigative team assisting my clients learned that Trump
called Epstein's West Palm Beach mansion on several occasions during the time period
most relevant to my clients' complaints; (b) Trump was quoted in a Vanity Fair article
about Epstein as saying "I've known Jeff for fifteen years. Terrific guy." "He's a lot
of fun to be with. It is even said that he likes beautiful women as much as I do, and
many of them are on the younger side. No doubt about it - Jeffrey enjoys his social
life." Jeffrey Epstein: International Moneyman of Mystery; He's pals with a passel of
Nobel Prize-winning scientists, CEOs like Leslie Wexner of the Limited, socialite
Ghislaine Maxwell, even Donald Trump. But it wasn't until he flew Bill Clinton,
Kevin Spacey, and Chris Tucker to Africa on his private Boeing 727 that the world
began to wonder who he is. By Landon Thomas Jr.; (c) I learned through a source
that Trump banned Epstein from his Maralago Club in West Palm Beach because
Epstein sexually assaulted an underage girl at the club; (d) Jane Doe No. 102's
complaint alleged that Jane Doe 102 was initially approached at Trump's Maralago by
Ghislaine Maxwell and recruited to be Maxwell and Epstein's underage sex slave; (e)
Mark Epstein (Jeffrey Epstein's brother) testified that Trump flew on Jeffrey Epstein's
plane with him (the same plane that Jane Doe 102 alleged was used to have sex with
underage girls) deposition of Mark Epstein, September 21, 2009 at 48-50; (f) Trump
visited Epstein at his home in Palm Beach - the same home where Epstein abused
minor girls daily; (g) Epstein's phone directory from his computer contains 14 phone
numbers for Donald Trump, including emergency numbers, car numbers, and numbers
to Trump's security guard and houseman. Based on this information, I believed that
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