Epstein Secrets

We represent defendants Jeffrey Epstein and ("Defendants") in the above- referenced lawsuit ("Action"). The Defendants intend to move to dismiss the Action based on, inter alia, the failure of Jane Doe 43 ("Plaintiff") to establish personal jurisdiction over the Defendants ("Motion to Dismiss"). The Pl

or good cause shown following notice to all parties and an opportunity for them to be heard. 13Y THE STATES DISTRICT JUDGE 6 EFTA00793046 To: Laura Menninger, Esq. Re: Giuffre v. Maxwell, Case No. 1S-cv-07433 United States District Court For the Southern District of New York March 17, 2016 Protective O

articularity or unreasonable, or otherwise seek the discovery of information that is neither relevant to the claims or defenses of any party to this Action nor reasonably calculated to lead to the discovery of admissible evidence 12. Plaintiff objects to the Interrogatories, including the Definitions

7 Fax: (212)-704-6288 Email: [email protected] [email protected] Counsel for Defendants Darren K. Indyke and Richard D. Kahn Laura Menninger, Esq. HADDON MORGAN FOREMAN P.C. 150 E. 10in Avenue Denver, CO 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: [email protected] Cou

he attends star studded charity gala On behalf of Action on Addiction Charlie Sheen cuts a casual figure whil

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 Defendant’s Motion For Summary Judgment I, Laura A. Menninger, declare as follows: 1. Iam an attorney at law duly licensed in the Sta

CLAUSE TO SUPPRESS ALL EVIDENCE OBTAINED FROM THE GOVERNMENT'S SUBPOENA TO BOLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Ghisla

or Boies Schiller had anything to do with the Government's decision to convene a grand jury to look into the matters that were the subject of the Action. On the contrary—the Government has advised the Court that it contacted Boies Schiller as part of its search for parties who might have been victim

CLAUSE TO SUPPRESS ALL EVIDENCE OBTAINED FROM THE GOVERNMENT'S SUBPOENA TO BOIES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON MORGAN & FOREMAN P.C. Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorn

or Boies Schiller had anything to do with the Government's decision to convene a grand jury to look into the matters that were the subject of the Action. On the contrary—the Government has advised the Court that it contacted Boies Schiller as part of its search for parties who might have been victim