Epstein Secrets

unsuccessfully — to arrange service through the Haddon Morgan firm. For example, on May 9, 2017, co-counsel for Jane Doe 43 (Ms. Sigrid McCawley at Boies Schiller) sent an email to Mr. Pagliuca as follows (id. at 3-4): From: Sigrid McCawley Sent: Tuesday, May 09, 017 4:33 PM To: Jeff Pagliuca Subject: Servi

RNATIVE SERVICE ON MAXWELL Plaintiff, Jane Doe 43, by and through the undersigned counsel, now responds to the letter motion on behalf of non-party Haddon, Morgan and Foreman, P.C. ("Haddon Morgan") requesting that the Court withdraw its order permitting alternative service of defendant Ghislaine Maxw

as entered. However, Haddon Morgan represents only that "had no notice of [the order] until after the Court entered the Order." Mot. at 2. Moreover, Haddon 4 EFTA00792800 Morgan undoubtedly had notice of the order when it received the summons and complaint on October 9, 2017. See Mot. at 1 (acknowle

tion that it properly was a recipient of the material: [W]hatever Cooper & Kirk's intentions in requesting and obtaining the Maxwell materials from Boies Schiller, the Maxwell Protective -footnote cont'd on next page- 10 EFTA00074919 Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page18 of 38 On July 23

ttendant EiAppellant/Petkioner DAppellet/Respondent MOVING ATTORNEY: Adam Mueller [name of attorney, with fon, address, phone number and e-mail) Haddon, Morgan and Foreman, P.C. Boies Schiller & Flexner LLP OPPOSING ATTORNEY: Sigrid McCawley Court- Judge/ Agency appealed from: Hon. Loretta A. Pre

tion that it properly was a recipient of the material: [W]hatever Cooper & Kirk's intentions in requesting and obtaining the Maxwell materials from Boies Schiller, the Maxwell Protective Order explicitly provides that (1) discovery materials designated CONFIDENTIAL cannot be EFTA00094806 Case 1:15-cv-07433-

REMAN July 29, 2020 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, r.0 Ty Gee 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 HI 303.832.2628 www.hmtlaw.com [email protected] Re:

tion that it properly was a recipient of the material: [W]hatever Cooper & Kirk's intentions in requesting and obtaining the Maxwell materials from Boies Schiller, the Maxwell Protective Order explicitly provides that (1) discovery materials designated CONFIDENTIAL cannot be EFTA00075057 Caest 131-63.403481

REMAN July 29, 2020 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, P C Ty Gee 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 HI 303.832.2628 www.hmllaw.com [email protected] Re:

OEC 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 All right. OK. I know people personally and professionally at Boies Schiller. I knew Mr. Haddon when I was in private practice. I may know people at Steptoe, but I'm not sure. Nothing about any of that affects anything that

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 All right. OK. I know people personally and professionally at Boies Schiller. I knew Mr. Haddon when I was in private practice. I may know people at Steptoe, but I'm not sure. Nothing about any of that affects anything that I do in the case.