Epstein Secrets

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:

Court," as referenced in Motion for Paul Cassell to Appear (Doc. #112), because defense counsel had not received any such supplemental materials. [Menninger Decl. Ex. A]. Ms. McCawley responded that her "staff is scanning them to you now. You should have them shortly." Id. At 5:49 p.m., Plaintiff's counsel se

en s Gresser LLP, to represent her in connection with legal matters in the United States at some indeterminate point in 2009. Def.'s Decl. of L.A. Menninger in Supp. Def.'s Resp. to Pl.'s Mot. to Compel Production of Does. Subject to Improper Privilege, ECF. No. 47, 3 EFTA_R1_00011979 EFTA01734189 (

ty participated in this email 19 EFTA R1 00011995 EFTA01734205 Case 1:15-cv-07433-RWS Document 125 Mled O5/02i16 Page 20 of 31 correspondence." Menninger Decl. 1 117 Supp. Reply at 5 n.2, Documents .11045-46 contain communications between Defendant and Barden; however, documents 81047-51 -include Gow (and

Dismiss. 10 EFTA00591588 Case 1:15-cv-07433-RWS Document 25 Filed 12/28/15 Page 13 of 13 Dated: December 28. 2015. Respectfully submitted, s/ Laura A. Menninger Laura A. Menninger (LM-1374) HADDON, MORGAN AND FOREMAN, P.C. East 10th Avenue Denver, CO 80203 Phone: Fax: Attorneys for Ghislaine Maxwell CER

concerning "numerous American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders." Menninger Decl., Ex. C at 5. Plaintiff's story is palpably incredible, as even Judge Marra suggested in his Order. In any event, New York courts uniformly agree g

f, v. GHISLATNE MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S RESPONSE IN OPPOSITION TO MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. EFTA00097395 Case 1:15-cv-07433-RWS Document 189 Filed 06/06/16 Page 2 of 11 Defendant Ghis

ached by Ghislaine Maxwell," and continuing that "Maxwell persuaded Jane Doe 143 (who was only fifteen years old) to come to Epstein's mansion ..." Menninger Decl., N. A at 26-29. No amount of "circumstantial evidence" can overcome the fact that Ms. Maxwell's statement was correct and that statements in the Jo