Epstein Secrets

S. Peluso Sher Tremonte, LLP 90 Broad Street, 23nd Floor New York, NY 10004 Counsel for Haddon, Morgan & Foreman, P.C. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Michael C. Miller 1114 Avenue of the Americas New York, NY 100

at Haddon Morgan — Jeff Pagliuca and Laura Menninger. See Edwards Aff., Exhibit 1, at 1. Based on his frequent 5 EFTA00792801 contacts with Mr. Pagliuca and Ms. Menninger, he understood that they had the ability to immediately contact Maxwell, via email or cellular telephone. Id. In connection with

Currently working on motions in limine and off to daughter's wedding tomorrow. I will try to get back to you on Monday or Tuesday with an answer. Jeffrey S. Pagliuca Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 Main 7 EFTA00792803 In follow up conversations, Mr. Pagliuca ind

to litigate on behalf of defendant Maxwell in this very Court and, thus, presumably has an effective way of communication with Maxwell. This Court (Koeltl, J.), has previously allowed service to be made through an attorney that was representing a client, explaining that the attorney "must know how to c

om: Laura Menninger < Sent: Tuesday, November 6.2018 4:16 PM To: Paul Cassell < Cc: ; Meredith Schultz >. Stan Pottinger Henderson < Link < ; Jeff Pagliuca Subject: Re: meet and confer on Ms. Maxwell's discovery production Paul - >: Brad Edwards ; Scott I will be with Ms Maxwell in her deposition on

018 8:07 PM To: Laura Mennin er Cc: Pottinger Pagliuca Subject: RE: meet and confer on Ms. Maxwell's di

rovide corroborating testimony to Plaintiff as well as destruction of documents and other evidence regarding what they had done." FAC at 65. Judge Koeltl has already recognized the breadth of the allegations in denying a motion to strike a part of the complaint dealing with earlier events. In particul

cute this action. The government has not articulated a cogent reason for that information to be kept from the other judicial officers. Sincerely, Jeffrey S. Pagliuca CC: Counsel of Record (via ECF) EFTA00088210

other judicial officers. Sincerely, Jeffrey S. Pagliuca CC: Counsel of Record (via ECF) EFTA00088210

uash. Similar cases in this district demonstrate the "non-standard" nature of the government's conduct regarding these subpoenas. For example, Judge Koeltl observed when considering whether to release a single deposition transcript to the government: "the Second Circuit has made clear that the Governme