South Africa
LocationRelationship Network
024.pdf
This is a Memorandum of Law filed by the defendants (Executors of the Estate of Jeffrey Epstein) in support of their motion to dismiss the plaintiff's complaint. The defendants argue that the plaintiff's claims of sexual assault and battery are time-barred by the applicable statutes of limitations in multiple jurisdictions (USVI, NY, NM, FL, France) and that exceptions like CPLR 215(8)(a) or equitable tolling do not apply. Additionally, the defendants argue that punitive damages are not recoverable against a deceased tortfeasor's estate under the laws of any relevant jurisdiction.
013.pdf
This document is a letter from plaintiff's counsel (Boies Schiller Flexner) to Judge Andrew L. Carter Jr. in the case *Bryant v. Indyke et al.*, dated January 29, 2020. The letter argues against the defendants' anticipated motion to dismiss, asserting that Juliette Bryant's claims are timely under New York statutes (CPLR § 215(8)(a) and § 213-c) and the doctrine of equitable estoppel due to Epstein's intimidation tactics. It details that Bryant was a resident of New York during the abuse (2002-2005 era) and was raped repeatedly by Epstein at his New York home.
012.pdf
This document is a letter from Bennet J. Moskowitz of Troutman Sanders LLP to Judge Andrew L. Carter Jr., dated January 24, 2020. It serves as a pre-motion letter outlining the Estate of Jeffrey Epstein's intent to move for dismissal of a lawsuit filed by Juliette Bryant. The Estate argues that Bryant's claims regarding alleged sexual abuse between 2002 and 2004 are time-barred by the statutes of limitations in New York, USVI, Florida, and New Mexico, and that she cannot rely on the Child Victims Act or tolling because she was an adult (age 20-22) at the time of the alleged incidents. Additionally, the letter argues that punitive damages cannot be recovered from a decedent's estate under the relevant laws.
001.pdf
This document is a legal complaint filed by Juliette Bryant against the executors of Jeffrey Edward Epstein's estate. It details allegations of sexual abuse and trafficking by Epstein, beginning when Bryant was 20 years old, and describes Epstein's extensive sex trafficking network and his previous legal actions and statements regarding his conduct.
EFTA00038153.pdf
This document is an email chain from October to November 2020 between Sigrid McCawley (Boies Schiller Flexner LLP) and a redacted individual coordinating with the DOJ regarding a meeting for Epstein victims. The discussion focuses on logistics for victims who cannot travel, listing client locations in the US, Spain, South Africa, and Australia, and addresses an unexpected RSVP from a victim not on the original client list. McCawley confirms she intends to attend the meeting in person.
EFTA00038037.pdf
This document contains an email thread from July 2020 involving a Detective from the NYPD/FBI Human Trafficking Task Force. A tipster forwarded a 2011 blog post written by a model who describes being recruited for Victoria's Secret, meeting Ghislaine Maxwell, and being flown on a private jet to Palm Beach where 'the man in charge' (implied to be Epstein) made a sexual advance. The model refused the advance and was immediately flown home.
EFTA00037130.pdf
This document is a formal 'Declaration of Renunciation' issued by UK Visas and Immigration on March 4, 2024. It confirms that an unnamed individual (name and DOB redacted), born in Johannesburg, South Africa, has renounced their British citizenship. The document specifies that the renunciation is contingent upon the individual holding or acquiring another nationality within six months. The document bears a 'Home Office London' seal and the reference number 033972218.
EFTA00026467.pdf
This Wall Street Journal newsletter from January 26, 2021, highlights the resignation of Apollo Global Management CEO Leon Black following an independent probe into his ties with Jeffrey Epstein. The report revealed Black paid Epstein $148 million for advice, though it stated Black was not involved in Epstein's criminal activities. The newsletter also covers general news including Janet Yellen's confirmation, Dominion Voting Systems suing Rudy Giuliani, and COVID-19 updates.
DOJ-OGR-00018198.jpg
This document is a page from a court transcript dated August 10, 2022, detailing the cross-examination of a witness named Alessi. The questioning focuses on Alessi's interactions with three women: Shelly Lewis (from the UK), Frances Hardinge (from South Africa), and Mandy Ellison (from South Africa). The witness confirms that Mandy Ellison was a lawyer for a 'Mr. Epstein'.
DOJ-OGR-00001136.jpg
This document is page 35 of a legal filing (Document 102) dated December 14, 2020, arguing for Ghislaine Maxwell's release on bail. It contends that her proposed $28.5 million bond package exceeds necessary requirements for ensuring her presence in court. The document features a table comparing Maxwell's proposed bail conditions (including private security and electronic monitoring) to those of other high-profile defendants like Bernie Madoff and Khashoggi, highlighting that her package is stricter than those previously granted release.
DOJ-OGR-00001129.jpg
This document is page 33 of a legal filing (dated Dec 14, 2020) in the case of United States v. Ghislaine Maxwell. It argues that Maxwell is not a flight risk because she has executed waivers of extradition and obtained expert reports (specifically from U.K. barrister David Perry) concluding she could not successfully resist extradition from the U.K. or France. The text cites various legal precedents (Salvagno, Karni, Chen, Khashoggi) to support the validity of extradition waivers as conditions of release.
DOJ-OGR-00000286.jpg
This document is a legal filing, page 13 of a motion in the case against Mr. Epstein, arguing for his pretrial release. It cites several legal precedents (United States v. Karni, United States v. Hanson, and Sabhnani) where courts ordered the release of defendants despite them being foreign nationals, having few ties to the U.S., facing serious charges, and substantial evidence of guilt. The core argument is that the potential for a significant sentence does not automatically preclude pretrial release.
DOJ-OGR-00002143.jpg
This document is page 19 of a legal filing (Document 97-22) in the case of United States v. Ghislaine Maxwell, authored by French attorney William Julié. It provides a legal analysis of the Extradition Treaty between France and the USA, arguing that unlike other treaties (such as the European Convention on Extradition), the US-France treaty does not explicitly prohibit the extradition of French nationals. It contrasts this with treaties France holds with countries like Morocco and China, and compares it favorably to the treaty with Canada.
DOJ-OGR-00002107.jpg
This legal document, filed on December 14, 2020, argues for the extradition of Ms. Maxwell to the United States. It contends that a U.S. trial would best serve the interests of the victims and that it is highly unlikely Ms. Maxwell could successfully oppose extradition on the grounds of her physical or mental health, as the legal threshold for such an argument is exceptionally high.
DOJ-OGR-00002012.jpg
This legal document, filed on December 14, 2020, argues for the approval of a proposed $28.5 million bail package for defendant Ms. Maxwell. It contends that this package is more than sufficient to ensure her appearance in court by comparing it to the less restrictive bail conditions of other high-profile defendants with significant financial means and foreign citizenships. A table is provided to illustrate these precedents, detailing bond amounts and conditions for defendants such as Madoff, Khashoggi, and others.
DOJ-OGR-00002005.jpg
This page is from a legal filing (Document 97) dated December 14, 2020, in the case of United States v. Ghislaine Maxwell. The defense argues that Maxwell should be granted bail conditions involving an extradition waiver, citing legal precedents (Salvagno, Karni, Chen, Khashoggi) where such waivers were accepted as assurances against flight. The document states Maxwell has obtained expert reports from French and UK experts (specifically David Perry regarding the UK) concluding that she would be unable to resist extradition back to the US if she fled to those countries after signing a waiver.
DOJ-OGR-00020047.jpg
This legal document, part of a court filing, argues on behalf of Ms. Maxwell by citing several past U.S. court cases where defendants waived extradition rights to demonstrate they were not a flight risk. It then introduces expert reports, specifically one from U.K. barrister David Perry, which conclude it is highly unlikely Ms. Maxwell could successfully resist extradition from the U.K. or France back to the United States, further supporting the argument that she is not a flight risk.
HOUSE_OVERSIGHT_019267.jpg
This document appears to be page 33 of a Freedom House report discussing censorship and historical revisionism in authoritarian regimes, specifically focusing on China under Xi Jinping and Russia under Putin. It details how the Chinese Communist Party suppresses discussion of the Cultural Revolution, the Great Leap Forward, and the Tiananmen Square massacre, while promoting nationalism and Maoist imagery. It also draws parallels to Russia's rehabilitation of Stalin and contrasts these approaches with countries like Germany and South Africa that have confronted their difficult histories. The document bears a 'HOUSE_OVERSIGHT' Bates stamp, indicating it was part of a document production for a congressional investigation.
HOUSE_OVERSIGHT_018584.jpg
This document appears to be a printout of a blog post or article (originally published on Carnal Nation) written by a sex educator working in South Africa. The text explores the ethical and practical conflicts between the author's 'sex-positive' American background and the necessity of promoting abstinence in South Africa due to the HIV epidemic (citing 40% positive rates in some groups). It mentions specific individuals like Agrippa Khathide and a partner referred to as 'Mr. Chastity,' ending with a link to the original online article. The document bears a House Oversight Bates stamp.
HOUSE_OVERSIGHT_031707.jpg
This document appears to be an email sent from an iPad containing the text of a political opinion piece (likely by Thomas Friedman, given the style and timeframe) criticizing Mitt Romney's 2012 visit to Israel. The text contrasts Romney's fundraising activities with Sheldon Adelson against his lack of engagement with Palestinian leadership, while praising the Obama administration's security support for Israel as confirmed by Ehud Barak. It concludes by urging US politicians to stop using the Israeli-Palestinian conflict for political gain. The document bears a House Oversight stamp.
HOUSE_OVERSIGHT_025998.jpg
This document is page 21 of a 'Global Equity Volatility Insights' report produced by Bank of America Merrill Lynch, dated August 9, 2016. It contains statistical data tables (Table 9 and Table 10) detailing market volatility metrics for developed and emerging markets as of August 5, 2016. The document bears the Bates stamp 'HOUSE_OVERSIGHT_025998', indicating it was part of a production to the House Oversight Committee, likely related to investigations involving financial records.
HOUSE_OVERSIGHT_026699.jpg
This document is page 19 of a financial report analyzing sovereign wealth fund investments in emerging markets, specifically focusing on India's potential compared to Brazil, Russia, and South Africa. It includes GDP data from the World Bank and charts tracking the attractiveness of the Indian private sector to sovereign investors between 2015 and 2017. The document bears a 'HOUSE_OVERSIGHT_026699' stamp, suggesting it was part of a document production to the US House Oversight Committee, likely related to investigations into financial institutions, though the text itself is purely economic analysis and does not mention Epstein.
HOUSE_OVERSIGHT_026686.jpg
This document is page 6 of a financial report (marked with House Oversight Bates stamp 026686) analyzing the global economic outlook as of early 2017. It discusses macro policy, geopolitical uncertainty, the end of Quantitative Easing, and the 'return gap' faced by sovereign investors and central banks. While part of the House Oversight documents (often associated with the Epstein investigation), this specific page contains general economic analysis and does not mention Epstein or specific individuals.
HOUSE_OVERSIGHT_017087.jpg
This document is a page from the participant directory for the World Economic Forum Annual Meeting held in 2011. It lists high-profile attendees including CEOs, government officials (such as Yves Leterme, Prime Minister of Belgium, and Ursula von der Leyen), and academics, detailing their roles, organizations, and countries of origin. The document contains a strict confidentiality notice regarding the use of participant information and bears a House Oversight Committee Bates stamp (HOUSE_OVERSIGHT_017087).
HOUSE_OVERSIGHT_017082.jpg
The document is a page from the World Economic Forum Annual Meeting 2011 participant list, bearing the Bates stamp HOUSE_OVERSIGHT_017082. It provides an alphabetical directory (J through K) of high-profile attendees including corporate executives, politicians (such as Boris Johnson and Paul Kagame), and journalists, listing their roles, organizations, and countries of origin. Of note in the context of Epstein-related inquiries is Scott B. Kapnick of Highbridge Capital Management, a firm with historical ties to Glenn Dubin and Epstein.
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