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regoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: Fax: Email: 21 /s/ Sigrid S. Mc
Jenkens & Gilchrist, 362 F. Supp. 2d 407 (S.D.N.Y. 2004) 6 F.D.I.C. v. Fidelity & Deposit Co. of Maryland, 45 F.3d 969 (5th Cir. 1995) 6 In re WorldCom, Inc. Securities Litigation, 2005 WL 375315 (S.D.N.Y. Feb. 17, 2005) 17 LiButti v. United States, 107 F.3d 110 (2d Cir. 1997) passim Rules Fe
ask that the Court simply apply the law in 25 Tillery. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00794661 107 H3v1giu2 1 Oh, Ms. Menninger reminds me, your Honor -- and I 2 think the Court and I are on the same page on this as well -- 3 the tax argument made by Mr. Cassell. Indeed, Ms
he kind of questions that have 16 been disapproved in the Second Circuit. And that's Brink's 17 Inc. v. City of New York, which is in the papers; WorldCom 18 Security Litigation, also in the papers; and LiButti itself. 19 These are not technical objections. It serves no legitimate 20 evidentiary p
, P.C. (212) 805-0300 EFTA00612355 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 H3v1giu2 107 Oh, Ms. Menninger reminds me, your Honor -- and I think the Court and I are on the same page on this as well -- the tax argument made by Mr. Cassell. Indeed, Ms. Maxw
he kind of questions that have 16 been disapproved in the Second Circuit. And that's Brink's 17 Inc. v. City of New York, which is in the papers; WorldCom 18 Security Litigation, also in the papers; and LiButti itself. 19 These are not technical objections. It serves no legitimate 20 evidentiary p
Entities connected to both Laura Menninger and WorldCom

Ghislaine Maxwell
PERSONJeffrey Pagliuca
PERSON
Jeffrey Epstein
PERSON
Prince Andrew
PERSONSouthern District
LOCATIONSigrid McCawley
PERSON
Colorado
LOCATION
David Boies
PERSON
Department of Justice
ORGANIZATION
Bradley Edwards
PERSON
Paul Cassell
PERSONthe Southern District
LOCATION
United States
LOCATION
Alan Dershowitz
PERSONSecond Circuit
ORGANIZATION
Virginia Giuffre
PERSONJane Doe
PERSON
Julie K. Brown
PERSON
U.S. Virgin Islands
LOCATIONLeon Black
PERSON