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BOIES, SCHILLER & FLEXNER LLP S6. York Nal shire r California a New Jersey 4 FACSIMILE COVER SHEET TO: Laura Menninger, Esq. Haddon, Morgan and Foreman, P.C. Fax No. Telephone No. FROM: Sigrid S. McCawley, Esq. DATE: February 26, 2016 RE: .r . Maxwell, Case no. 15-cv-07433-RWS Total Number
otential witnesses; h. any person (1) who authored or received the particular Protected Material; (2) who has or had at any point in time access to the Protected Material outside of the context of this action; or (3) for which there is a good faith basis to conclude that the individual has earlier received or seen su
ER & FLEXNER LLP Ngsv York I Washinntore.DCli Florida i California &New Jerse FACSIMILE COVER SHEET TO: Laura Menninger, Esq. Haddon, Morgan and Foreman, P.C. Fax No. Telephone No. FROM: Sigrid S. McCawley, Esq. DATE: February 26, 2016 RE: r. Maxwell, Case no. 15-cv-07433-RWS Total Number of
otential witnesses; h. any person (1) who authored or received the particular Protected Material; (2) who has or had at any point in time access to the Protected Material outside of the context of this action; or (3) for which there is a good faith basis to conclude that the individual has earlier received or seen su
0 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, P C Ty Gee 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 HI 303.832.2628 www.hmllaw.com [email protected] Re: Reconsideration of
otential witnesses; h. any person (1) who authored or received the particular Protected Material; (2) who has or had at any point in time access to the Protected Material outside of the context of this action; or (3) for which there is a good faith basis to conclude that the individual has earlier received or seen su
Entities connected to both Foreman and the Protected Material

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONHaddon
PERSONLaura Menninger
PERSONSigrid McCawley
PERSON
David Boies
PERSONBates
PERSONthe Southern District
LOCATION
New York
LOCATIONSCHILLER & FLEXNER LLP
ORGANIZATIONChallenging Designations Of Protected Material
ORGANIZATIONthe Receiving Party
ORGANIZATIONCONFIDENTIALshall
ORGANIZATIONthe Producing Party
ORGANIZATIONthe non-party
ORGANIZATION