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served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: Fax: Email: 21 /s/ Sigrid S. McCawley Sigrid S. McCawl
ted by CM/ECF. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 1
Jenkens & Gilchrist, 362 F. Supp. 2d 407 (S.D.N.Y. 2004) 6 F.D.I.C. v. Fidelity & Deposit Co. of Maryland, 45 F.3d 969 (5th Cir. 1995) 6 In re WorldCom, Inc. Securities Litigation, 2005 WL 375315 (S.D.N.Y. Feb. 17, 2005) 17 LiButti v. United States, 107 F.3d 110 (2d Cir. 1997) passim Rules Fe
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
he kind of questions that have 16 been disapproved in the Second Circuit. And that's Brink's 17 Inc. v. City of New York, which is in the papers; WorldCom 18 Security Litigation, also in the papers; and LiButti itself. 19 These are not technical objections. It serves no legitimate 20 evidentiary p
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
he kind of questions that have 16 been disapproved in the Second Circuit. And that's Brink's 17 Inc. v. City of New York, which is in the papers; WorldCom 18 Security Litigation, also in the papers; and LiButti itself. 19 These are not technical objections. It serves no legitimate 20 evidentiary p
Entities connected to both Jeffrey Pagliuca and WorldCom

Ghislaine Maxwell
PERSONLaura Menninger
PERSON
Jeffrey Epstein
PERSON
Prince Andrew
PERSONSouthern District
LOCATION
Colorado
LOCATION
David Boies
PERSONSigrid McCawley
PERSON
Department of Justice
ORGANIZATION
Bradley Edwards
PERSON
United States
LOCATIONthe Southern District
LOCATION
Paul Cassell
PERSONSecond Circuit
ORGANIZATION
Stephen Hawking
PERSON
Virginia Giuffre
PERSON
Julie K. Brown
PERSON
Alan Dershowitz
PERSON
Southern District of New York
ORGANIZATIONJane Doe
PERSON