The defense attorney for Ghislaine Maxwell argues that the testimony of Eva Dubin, Michelle Healy, a...

Court Filing - Letter to Judge: 723

The defense attorney for Ghislaine Maxwell argues that the testimony of Eva Dubin, Michelle Healy, and Kelly Bovino is relevant, material, and exculpatory, contradicting Jane's testimony about group sexualized massages involving Maxwell and Jeffrey Epstein. The defense asserts that excluding this testimony would violate Maxwell's right to present a defense and confront her accusers.

EFTA01442948

EFTA Document EFTA01711655

5(19/22, 3:52 PM SEA At. "250SC. fktmct

5(19/22, 3:52 PM SEA At. "250SC. fktmct JcereY Epsteh - Wildpedla Epstein a massage". She claims she was taken to his mansion, where he exposed himself and had sexual intercourse with her, and paid her $200 immediately afterward.1io61 A similar $50-million suit was filed in March 2008, by a different woman, who was represented by the same lawyer.E•g-91 These and several similar lawsuits were dismissed.1139-) All other lawsuits have been settled by Epstein out of court' ll Epstein made many art-pl-atirt r s_ettlements with alleged victims.W23 - - - _ E_XCAt "-Vet 5sE RItACt PnOi- CiOR °NICER • - 40L'aritfrieerPROS1 1701-i0.Ni o> SIE•us) i1/44".,e036( C ; Perversion of Justice, Miami Herald, November 30, 2018. Victims' rights: Jane Does v. United States (2014)*SC7ck%A L. ne,OSC Rt p Rom N)Eiszci poS IT c"),3 A December 3o, 2014, federal civil suit was filed in Florida by Jane Doe 1 ([REDACTED - Survivor]) and Jane Doe 2 against the United States for violations of the Crime Vi

EFTA Document EFTA01361573

UNCLASSIFIED/NOR OFFICIAL USE ONLY

UNCLASSIFIED/NOR OFFICIAL USE ONLY FBI INTER\ %I. USE ONLY— DO NOT DISSEMINATE EXTERNALLY 1 nwplate 10.1.2N21 Tactical intelligence Report FBI New York, ID-13 16 March 2022 SOD-NY-3027571-INTELPRODS (U) This document is classified UnclassifiedfiFor Official Use Only. (U) This document is only for FBI internal use. Do not externally disseminate this product. (U) Tactical Intelligence Report template approved for fiscal year 2022. as of I October 2021. (U//FOUO) Research and Key Findings for Michelle Healy, a Person of Interest for Alleged Defense Witnesses in the Ghislaine Maxwell Trial (U) Executive Summary (U/IFOUO) FBI New York Intelligence Division conducted research on suspected defense witnesses for the Ghislaine Maxwell trial in order to identify the individuals and any related derogatory information. FBI New York Criminal Division squad C-20 is investigating Ghislaine Maxwell in a child sex trafficking investigation based on information regarding several victim