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25th day of May, 2016, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: Fax: Email: Copies of this filing were also provided by
CM/ECF system. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 1
sel to seek agreement that she would accept service of the subpoena in this matter. See McCawley Decl. at Exhibit 5, Electronic Correspondence with Bruce Reinhart, of McDonald Hopkins, LLP in West Palm Beach, Florida. Mr. Reinhart represented that Ms. refused to allow her counsel to accept service of the sub
ly, your Honor, I think you can 10 just see from the upset there what's going to be happening at 11 this trial. This is the direct quote from Mr. Pagliuca. 12 "Fantastical conspiracy". That's going to be the argument from 13 the other side. They're obviously entitled to advance that 14 argument. B
m the fact that they were evading service 14 while we were trying to obtain their testimony last year. 15 Eventually they show up with lawyers, a Bruce Reinhart I think 16 is an Epstein lawyer; I think at some point Ms. had 17 Mr. Goldberger, who's an attorney for Mr. Epstein now. They've 18 both made
: In reply, your Honor, I think you can just see from the upset there what's going to be happening at this trial. This is the direct quote from Mr. Pagliuca. "Fantastical conspiracy". That's going to be the argument from the other side. They're obviously entitled to advance that argument. But that's wh
y they show up is an Epstein lawyer; I Mr. Goldberger, with lawyers, a think at some point who's an attorney for Mr. their testimony last year. Bruce Reinhart I think Ms. Marcinkova had Epstein now. They've both made significant efforts in our view the conspiracy con conspiracy is trying to conceal wha
Entities connected to both Jeffrey Pagliuca and Bruce E. Reinhart

Jeffrey Epstein
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Ghislaine Maxwell
PERSONLaura Menninger
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Michael Cohen
PERSONSouthern District
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Prince Andrew
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Bradley Edwards
PERSONJack Goldberger
PERSONJane Doe
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Paul Cassell
PERSONCohen & Gresser LLP
ORGANIZATIONJack Scarola
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Sarah Kellen
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Colorado
LOCATIONBates
PERSONSpencer Kuvin
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Salt Lake City
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Kenneth Marra
PERSONScott Rothstein
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Alan Dershowitz
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