Text extracted via OCR from the original document. May contain errors from the scanning process.
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Thanks for looking.
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To:
I haven't been able to find anything in which Maxwell's attorneys claim they don't know where Maxwell is. That
statement was only reported on (as best I can tell) in this article
(https://creativedestructionmed ia.cominews/politics/2020/01/23/ghisla i ne-maxwell s-lawyers-adm it-they-dont-know-
where-she-is-either/), which refers to a letter filed with Judge Preska in January 2020, and dated December 2019. The
article claims that the letter admitted Maxwell's lawyers don't know where their client is. Maxwell's attorneys filed one
letter from that time period to Judge Preska that I've found. That letter does not include any suggestion that Maxwell's
counsel does not know where Maxwell is. Rather, the letter cites to newspaper articles about the frenzied attempts of
reporters to track Maxwell down. So seems that the article misrepresented the letter from Maxwell's attorneys.
In case it's helpful, though, I found a couple orders permitting alternative service because of plaintiffs' inability to serve
Maxwell.
Here is a text order in
case approving alternative service after Maxwell's counsel refused to accept service.
06/15/2020
45
ORDER granting 43 Motion To Approve Alternate Service on Defendant Ghislaine Maxwell
("Maxwell"). Plaintiffs motion is unopposed, and, based on Plaintiffs representations regarding
her unsuccessful efforts to locate Maxwell's current residence, her fruitless attempts to serve
Maxwell at multiple locations, her equally fruitless attempts to contact Maxwell via several
email addresses publicly associated with Maxwell, and her rejected request to Maxwell's
known litigation counsel to accept service on Maxwell's behalf, this Court finds that Plaintiff has
adequately demonstrated that she has made diligent efforts to effect service, and that personal
service would be impracticable. See Ransome v. Epstein, No. 17cv616 (JGK), 2018 WL 637421,
at *1 (S.D.NY. Jan. 30, 2018); see also Farmer v. lndyke, No. 19cv10475 (LGS)(DF) (Text Order,
dated Feb. 12, 2020). This Court further finds that Plaintiff's provision of a copy of the
Summons and Complaint by email to Maxwell's current counsel of record in the Farmer case
(see Declaration of Robert S. Glassman, dated May 27, 2020 (Dkt. 43-2), Ex. 3) was reasonably
calculated to place Maxwell on notice of this suit and to constitute sufficient service under the
circumstances presented here. No later than 6/18/20, Plaintiff is directed to serve Maxwell with
a copy of this Text Order by the same means (i.e., by email to Maxwell's counsel of record in the
Farmer case), and to file proof of such service on the Docket of this action. Maxwell may then
have until 7/9/20 to move, answer, or otherwise respond to the Complaint. (HEREBY ORDERED
by Magistrate Judge Debra Freeman)(Text Only Order) (Freeman, Debra) (Entered: 06/15/2020)
And here is a similar text order granting the same request a
case after Maxwell's counsel refused to accept
service.
EFTA00020397
06/15/2020
45
ORDER granting 43 Motion To Approve Alternate Service on Defendant Ghislaine Maxwell
("Maxwell"). Plaintiffs motion is unopposed, and, based on Plaintiff's representations regarding
her unsuccessful efforts to locate Maxwell's current residence, her fruitless attempts to serve
Maxwell at multiple locations, her equally fruitless attempts to contact Maxwell via several
email addresses publicly associated with Maxwell, and her rejected request to Maxwell's
known litigation counsel to accept service on Maxwell's behalf, this Court finds that Plaintiff has
adequately demonstrated that she has made diligent efforts to effect service, and that personal
service would be impracticable. See Ransome v. Epstein, No. 17cv616 (JGK), 2018 WL 637421,
at *1 (S.D.N:Y. Jan. 30, 2018); see also Farmer v. Indyke, No. 19cv10475 (LGS)(DF) (Text Order,
dated Feb. 12, 2020). This Court further finds that Plaintiff's provision of a copy of the
Summons and Complaint by email to Maxwell's current counsel of record in the Farmer case
(see Declaration of Robert S. Glassman, dated May 27, 2020 (Dkt. 43-2), Ex. 3) was reasonably
calculated to place Maxwell on notice of this suit and to constitute sufficient service under the
circumstances presented here. No later than 6/18/20, Plaintiff is directed to serve Maxwell with
a copy of this Text Order by the same means (i.e., by email to Maxwell's counsel of record in the
Farmer case), and to file proof of such service on the Docket of this action. Maxwell may then
have until 7/9/20 to move, answer, or otherwise respond to the Complaint. (HEREBY ORDERED
by Magistrate Judge Debra Freeman)(Text Only Order) (Freeman, Debra) (Entered: 06/15/2020)
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>
>;
Could you guys possibly locate the transcript or filing where GM's attorneys said they did not know where she was? I tried
calling Sigrid but didn't reach her today. That would be a big help. Thanks team.
Assistant United States Attorney
Southern District of New York
One Saint Andrew's Plaza
New York, NY 10007
EFTA00020398