Epstein Secrets

MENT REOUEST NO. 1 Produce all documents that Your attorneys reviewed and/or relied upon in the March 21, 2016, meet and confer discussion when Mr. Pagliuca stated that (1) Plaintiff made false allegations concerning her sexual assault; (2) she made them in roughly the same time frame that Plaintiff was

regard to this Request, without further conferral. Dated: May 16, 2016 Respectfully submitted, s/Laura A.Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) AND FOREMAN, P.C. Denver, CO 80203 Phone: Fax: Attorneys for Ghislaine Maxwell 23 EFTA00091375 CERTIFICATE OF SERVICE I cert

g any alleged illegal activity involving Plaintiff from the Relevant Period. This request includes, but is not limited to, any documents concerning the Roadhouse Grill in Florida. RESPONSE: Ms. Maxwell objects to this Request as vague and confusing. Ms. Maxwell is unaware of all illegal activities in which Plainti

D FOREMAN, P.C. Attorneys for Defendant 20 BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. 21 22 23 24 25 SO

P.C. Attorneys for Defendant 20 BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. 21 22 23 24

at entire time. 20 It got quashed because it had been such a long passage of time. 21 THE COURT: Who was the employer? 22 MS. MENNINGER: It was the Roadhouse Grill, your 23 Honor. It was a burger joint. And she was working at that 24 Roadhouse Grill in March of 2002 during the period of time she 25 claims

GAN AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRICT R (2

EMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRICT

try during that entire time. It got quashed because it had been such a long passage of time. THE COURT: Who was the employer? MS. MENNINGER: It was the Roadhouse Grill, your Honor. It was a burger joint. And she was working at that Roadhouse Grill in March of 2002 during the period of time she claims that she was