Epstein Secrets

EMORANDUM OF LAW IN OPPOSITION TO EXTENDING DEADLINE TO COMPLETE DEPOSITIONS AND MOTION FOR SANCTIONS FOR VIOLATION OF RULE 45 Laura A. Menninger Jeffrey S. Pagliuca HADDON. MORGAN, AND FOREMAN, P.C. East 10th Avenue Denver, CO 80203 303.831.7364 EFTA00605112 Case 1:15-cv-07433-RWS Document 228 Filed 06/20/

LATION OF RULE 45 Laura A. Menninger Jeffrey S. Pagliuca HADDON. MORGAN, AND FOREMAN, P.C. East 10th Ave

e. She removed, 18 EFTA00605132 Case 1:15-cv-07433-RWS Document 228 Filed 06/20/16 Page 22 of 29 for example, witnesses and but added Senators George Mitchell, Bill Richardson and Les Wexner. Then between March 11 and June 1, a few weeks before the discovery cut-off, Plaintiff added 20 more witnesses, in

xample, witnesses and but added Senators George Mitchell, Bill Richardson and Les Wexner. Then between M

Bloomberg, "The government's failure to provide the evidence makes it impossible for Maxwell to prepare her defense, the British socialite's lawyer Jeffrey Pagliuca said Friday in a letter to U.S. District Judge Alison Nathan." As an illustration, the indictment does not provide exact "dates for when Maxwell co

ration, the indictment does not provide exact "dates for when Maxwell committed the alleged crimes, only saying they occurred between 1994 and 1997, Pagliuca said." He wrote, "Neither the indictment nor the discovery inform Ms. Maxwell about critical information necessary to prepare her defense." Teenag

Enquirer <https://wvvw.usatoday.corn/story/news/nation/2020/10/24/michael-mearan-charged- sex-trafficking/6027744002/> (10/24, Hunt, Grasha, Dufour, Mitchell, 223K) reported former Portsmouth, Ohio city councilman and still-practicing attorney Michael "Mearan was arrested on human trafficking, racketeerin

Bloomberg, "The government's failure to provide the evidence makes it impossible for Maxwell to prepare her defense, the British socialite's lawyer Jeffrey Pagliuca said Friday in a letter to U.S. District Judge Alison Nathan." As an illustration, the indictment does not provide exact "dates for when Maxwell com

ation, the indictment does not provide exact "dates for when Maxwell committed the alleged crimes, only saying they occurred between 1994 and 1997, Pagliuca said." He wrote, "Neither the indictment nor the discovery inform Ms. Maxwell about critical information necessary to prepare her defense." Teenag

g to the court documents." Former Ohio City Councilman Arrested On Human Trafficking Charges. The Cincinnati Enquirer (10/24, Hunt, Grasha, Dufour, Mitchell, 223K) reported former Portsmouth, Ohio city councilman and still-practicing attorney Michael "Mearan was arrested on human trafficking, racketeeri

Denver, CO 80203 By: Laura A. Henninger, Esq. Jeffrey S. Pagliuca, Esq. USDC SDNY DOCUMENT ELECTRONICAL:Y .FILED DOC

O 80203 By: Laura A. Henninger, Esq. Jeffrey S. Pagliuca, Esq. USDC SDNY DOCUMENT ELECTRONICAL:Y .FILED

te and safeguard the provision of legal advice; "to ensure that one seeking legal advice will be able to confide fully and freely in his attorney." Mitchell, 58 N.Y.2d at 373. New York law provides: Unless the client waives the privilege, an attorney or his or her employee, or any person who obtains wi

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can yo

ejecting claim that a "failure to inform [the defendant] of the Fifth Amendment privilege barred use of his confession at trial"); United States v. Mitchell, 966 F.2d 92, 100 (2d Cir. 1992) ("Inculpatory statements are not involuntary when they result from a desire to cooperate, or from a defendant's ig

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can yo

ejecting claim that a "failure to inform [the defendant] of the Fifth Amendment privilege barred use of his confession at trial"); United States v. Mitchell, 966 F.2d 92, 100 (2d Cir. 1992) ("Inculpatory statements are not involuntary when they result from a desire to cooperate, or from a defendant's ig

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can yo

ejecting claim that a "failure to inform [the defendant] of the Fifth Amendment privilege barred use of his confession at trial"); United States v. Mitchell, 966 F.2d 92, 100 (2d Cir. 1992) ("Inculpatory statements are not involuntary when they result from a desire to cooperate, or from a defendant's ig

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. 123 EFTA

ejecting claim that a "failure to inform [the defendant] of the Fifth Amendment privilege barred use of his confession at trial"); United States v. Mitchell, 966 F.2d 92, 100 (2d Cir. 1992) ("Inculpatory statements are not involuntary when they result from a desire to cooperate, or from a defendant's ig

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can yo

ejecting claim that a "failure to inform [the defendant] of the Fifth Amendment privilege barred use of his confession at trial"); United States v. Mitchell, 966 F.2d 92, 100 (2d Cir. 1992) ("Inculpatory statements are not involuntary when they result from a desire to cooperate, or from a defendant's ig