Epstein Secrets

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

nihan United States Courthouse 500 Pearl Street New York, New York 10007-1312 RE: Jane Doe 43 v. Epstein, et al.,No.17 Civ. 616 (JGK) Dear Judge Koeltl: Steptoe STEPTOS E JOHNSON LIP We represent defendants Jeffrey Epstein and ("Defendants") in the above- referenced lawsuit ("Action"). The Defend

Michael C. Miller 1114 Avenue of the Americas www.steptoe.com SUBMITTED UNDER SEAL July 14, 2017 Hon. John G. Koeltl United States District Court, Southern District of New York Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, New York

enerated by CM/ECF. Kimo S. Peluso Sher Tremonte, LLP 90 Broad Street, 23nd Floor New York, NY 10004 Counsel for Haddon, Morgan & Foreman, P.C. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Michael C. Miller 1114 Avenue of the Am

— Jeff Pagliuca and Laura Menninger. See Edwards Aff., Exhibit 1, at 1. Based on his frequent 5 EFTA00792801 contacts with Mr. Pagliuca and Ms. Menninger, he understood that they had the ability to immediately contact Maxwell, via email or cellular telephone. Id. In connection with the current lawsui

to litigate on behalf of defendant Maxwell in this very Court and, thus, presumably has an effective way of communication with Maxwell. This Court (Koeltl, J.), has previously allowed service to be made through an attorney that was representing a client, explaining that the attorney "must know how to c

age. Professor Cassell is admitted to the Utah State Bar. but not the bars of other states. Any views he expresses in this email are his own. From: Laura Menninger Sent: Tuesday, November 6.2018 5:55 PM To: Paul Cassell Cc: Pottinger Pagliuca Subject: Re: meet and confer on Ms. Maxwell's discovery producti

rovide corroborating testimony to Plaintiff as well as destruction of documents and other evidence regarding what they had done." FAC at 65. Judge Koeltl has already recognized the breadth of the allegations in denying a motion to strike a part of the complaint dealing with earlier events. In particul