Epstein Secrets

eclare as follows: 1. Iam an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. Iam a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit

Court notes that, regardless of which motion it considers, the same standard governs the addition of parties under Rule 21 and Rule 15. See Goston v. Potter, No. 08-cv-478 FJS ATB, 2010 WL 4774238, at *5 (N.D.N.Y. 2010) (citing Bridgeport Music, Inc. v. Universal Music Grp., Inc., 248 F.R.D. 408, 412 (S.D

rs, the same standard governs the addition of parties under Rule 21 and Rule 15. See Goston v. Potter, No. 08-cv-478 FJS ATB, 2010 WL 4774238, at *5 (N.D.N.Y. 2010) (citing Bridgeport Music, Inc. v. Universal Music Grp., Inc., 248 F.R.D. 408, 412 (S.D.N.Y. 2008)). 4 GIUFFRE002847 HOUSE_OVERSIGHT_014680

eclare as follows: 1. Iam an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. Iam a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit

Court notes that, regardless of which motion it considers, the same standard governs the addition of parties under Rule 21 and Rule 15. See Goston v. Potter, No. 08-cv-478 FJS ATB, 2010 WL 4774238, at *5 (N.D.N.Y. 2010) (citing Bridgeport Music, Inc. v. Universal Music Grp., Inc., 248 F.R.D. 408, 412 (S.D

(S.D.N.Y. 2005) has been a party to lawsuits in the South- ern District of New York, both as a plain- tiff and defendant.

l discovery. In evaluating jurisdic- tional motions, district courts enjoy broad discretion in deciding whether to order discovery. See, eg., APWU v. Potter, 348 F.3d 619, 627 (2d Cir.2003) (noting a court may “devis[e] the procedures [to] ferret out the facts pertinent to jurisdiction”); Marine Midland B