Epstein Secrets

20, denying Ms. Maxwell's motion to reconsider. Dated: July 29, 2020. Respectfully submitted, s/ Laura A. Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) Ty Gee (pro hac vice) HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Ghislaine Maxwell 1 EFTA00076389 CasastrabiAZI71432)IaAini

Sorry. No. 6 Thanks very much. 7 MR. CASSELL: Thank you, your Honor. 8 THE COURT: Anything from the defense. 9 MR. PAGLIUCA: Yes, your Honor. Jeff Pagliuca on 10 behalf of Ms. Maxwell. 11 Your Honor, I have never opposed a pro hac motion in 12 my 34 years of practice, so this is a first for me. But

23 24 25 Case 20-2413, Document 44, 08/20/2020, 2913556, Page67 of 78 K7N9GIUD App.-0841 150. Declaration of Mister how does he say it, Mr. Pagliuca? Say it again. MS. MENNINGER: Pagliuca. THE COURT: Mr. Pagliuca in opposition to the motion to compel. Unseal. 150-1. Additional pages from Ms. M

statements by Plaintiff, Plaintiff's counsel, the United States Attorney for the Southern District of New York, and the Attorney General for the U.S. Virgin Islands" about those investigations, (id.), carried with it the clear implication that Ms. Maxwell could find herself subject to investigation and

ates Attorney for the Southern District of New York BY: Assistant United States Attorneys HADDON MORGAN AND FOREMAN Attorneys for Defendant BY: JEFFREY S. PAGLIUCA CHRISTIAN R. EVERDELL LAURA A. MENNINGER -and- BOBBI C. STERNHEIM -and- RENATO STABILE Also Present: District Judge , FBI NYPD Sunny Dresche

would not make sense to return for one day of that week. So, really, it would be a 10-day break in the trial. I don't think that makes sense, Mr. Pagliuca. I know I mentioned that, but I'm not sure I had that fully in mind at the time, and that's practically what we would be talking about. MR. PAGLIU

tein? A. Every time we went to the St. Thomas U.S. Virgin Islands, where the island was located. Q. About how often did you fly Mr. Epstein to the U.S. Virgin Islands? A. Had been every week, every ten days, if we weren't elsewhere in the world, but it was a regular destination. Q. And why did you go to

4 K7N9GIUD 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 150. Declaration of Mister -- how does he say it, Mr. Pagliuca? Say it again. MS. MENNINGER: Pagliuca. THE COURT: Mr. Pagliuca in opposition to the motion to compel. Unseal. 150-1. Additional pages from Ms. M

statements by Plaintiff, Plaintiff's counsel, the United States Attorney for the Southern District of New York, and the Attorney General for the U.S. Virgin Islands" about those investigations, (id.), carried with it the clear implication that Ms. Maxwell could find herself subject to investigation and