Epstein Secrets

ver his objection that he is a resident of the U.S. Virgin Islands. See. e.g., Menninger Decl., Ex. G (Motion to Quash Subpoena on Jeffrey Epstein, Broward County, Florida, 15.000072). Yet, all of Plaintiff's purported attempts at service on Mr. Epstein were in New York. 12 EFTA00605126 Case 1:15-cv-07433-

. For example, Plaintiff issued a 12 McCawley Decl. in Support of Request to Exceed Ten Deposition Limit, Exhibit I (Doc. # 173.1) at 28 (Letter of Menninger to McCawley (Feb. 25, 2015) ("I would suggest that rather than repeated entails on the topic of scheduling the various depositions in this case, or

FENDANT'S COMBINED MEMORANDUM 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 Docu

bmissions by attorneys McCawley, Cassell and Edwards. To wit: Messrs. Cassell and Edwards, and Ms. McCawley, on April 11, 2016, filed a pleading in Broward County, Florida court captioned: "Plaintiffs and Non-Party Notice Regarding the Parties' Joint Stipulation of Dismissal." Menninger Decl. at Ex. B. In tha

continues to oppose the motions for admission pro hac vice by these applicants. Dated: April 21, 2016. EFTA00605451 Respectfully submitted, /s/ Laura A. Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca HADDON, MORGAN AND FOREMAN, P.C. 150 East 10ih Avenue Denver, CO 80203 Phone: 303.831.7364 Fax:

fendant in an action captioned Edwards and Edwards, Plaintiffs and Counterclaim Defendants v. Dershowitz, 15-000072 pending in the Circuit Court in Broward County, Florida. The subject of that litigation includes allegations made by Mr. Edwards during his representation of the Plaintiff in this matter about H

of Bradley James Edwards or, Alternatively, to Modify the Protection Order to Restrict Mr. Edwards's Access to Information Designated Confidential Laura A. Menninger Jeffrey S. Pagliuca HADDON. MORGAN, AND FOREMAN, P.C. East 10th Avenue Denver, CO 80203 EFTA00595640 Case 1:15-cv-07433-RWS Document 88 Filed 04

fendant in an action captioned Edwards and Edwards, Plaintiffs and Counterclaim Defendants v. Dershowitz, 15-000072 pending in the Circuit Court in Broward County, Florida. The subject of that litigation includes allegations made by Mr. Edwards during his representation of the Plaintiff in this matter about H

Bradley James aim, ards or, Alternatively, to Modify the Protection Order to Restrict Mr. Edwards's Access to Information Designated Confidential Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. East 10th Avenue Denver, CO 80203 EFTA00595633 Case 1:15-cv-07433-RWS Document 88 Filed 04/

F NEW YORK pane eee ene een enenenee X VIRGINIA L. GIUFFRE, : Plaintiff, V. 15-cv-07433-RWS GHISLAINE MAXWELL, : Defendant. . ee X Declaration of Laura A. Menninger in Support of Response in Opposition to Plaintiff's Omnibus Motion in Limine I, Laura A. Menninger, declare as follows: 1. Iam an attorney at law d

dwards, Paul G. Cassell, and Alan M. Dershowitz have resolved their disputes and have agreed to settle the claims raised in an action pending in the Broward County, Florida Circuit Court. Since being appointed by Circuit Court Judge Thomas Lynch IV last fall, it has been a privilege to act as the mediator and as