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based on diversity jurisdiction which is determined as of the date of the filing of the complaint. See 28 U.S. Code § 1332(a); see also LeBlanc v. Cleveland, 248 F.3d 95, 100 (2d Cir. 2001). The complaint was filed on September 21, 2015 at which time Plaintiff was living in Colorado and Defendant Ghisla
nted by the Plaintiff in her case in chief, Ms. Maxwell may offer testimony from the following witnesses at trial: 1. Ghislaine Maxwell (live) c/o Laura A. Menninger, Esq. Haddon, Morgan & Foreman, P.C. 150 E. 10th Ave. Denver, CO 80203 2. Kathy Alexander (live) Michaelhouse Pvt Bag X1 Balgowan KwaZulu-Natal 3
based on diversity jurisdiction which is determined as of the date of the filing of the complaint. See 28 U.S. Code § 1332(a); see also LeBlanc v. Cleveland, 248 F.3d 95, 100 (2d Cir. 2001). The complaint was filed on September 21, 2015 at which time Plaintiff was living in Colorado and Defendant Ghisla
ented by the Plaintiff in her case in chief, Ms. Maxwell may offer testimony from the following witnesses at trial: 1. Ghislaine Maxwell (live) do Laura A. Menninger, Esq. Haddon, Morgan & Foreman, P.C. 150 E. 10th Ave. Denver, CO 80203 2. Kathy (live) 3. Miles (live) 4. Philip Barden (live) Devonshires So
ITED COUNSEL-CONDUCTED VOIR DIRE Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 303-831-7364 Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 225 Broa
Page: EFTA00011096 →challenges through attorney-conducted voir dire. The attorneys have more in-depth knowledge of the case than the Court. See, e.g., United States v. Cleveland, 1997 WL 2554 at *3 (E.D. LA. Jan. 2, 1997). Important follow-up questions are more likely to occur to an advocate than a judge for several reasons,
Page: EFTA00011107 →Entities connected to both Cleveland and Laura Menninger

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSONJeffrey Pagliuca
PERSON
Michael Cohen
PERSON
Prince Andrew
PERSON
Denver
LOCATIONSouthern District
LOCATION
Colorado
LOCATIONBobbi C. Sternheim
PERSON
Department of Justice
ORGANIZATIONCohen & Gresser LLP
ORGANIZATION
Donald Trump
PERSONLeon Black
PERSON
United States
LOCATION
Virginia Giuffre
PERSON
Julie K. Brown
PERSON
George W. Bush
PERSONSigrid McCawley
PERSON
Alison J. Nathan
PERSON
Joe Biden
PERSON