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3, 2014) (internal quotation marks omitted)). Moreover, at least one New York court has found that British privilege law is "apparently similar" to New York's. Aetna Cas. & Sur. Co. v. Certain Underwriters at Lloyd's London, 4 "Where there is no attorney involved in the communication ..., there can be no
uffre v. Maxwell, No. 15 CIV. 7433 (RWS), 2016 WL 831949, at *2 n.2 (S.D.N.Y. Feb. 29, 2016) ("Because New York has the most significant interest, New York law applies."). The potential litigation for which Defendant sought Barden's advice never came to frOition and no • pending issues in or relating
S. McCawley, Esq. Meredith L. Schultz, Esq. Counsel for Defendants HADDON, MORGAN AND FOREMAN, P.C. 150 East Tenth Avenue Denver, CO 80203 By: Laura A. Henninger, Esq. Jeffrey S. Pagliuca, Esq. USDC SDNY DOCUMENT ELECTRONICAL:Y .FILED DOC #: DATE FILED: ) (,) 1 EFTA R1 00011977 EFTA01734187 Case 1:
ur review at 500 Pearl in the spring. The HC images come from two sources: First, there were HC images recovered from the CDs seized from Epstein's New York residence. Second, there were HC images and videos recovered from the electronic devices seized from Epstein during his arrest, the search of his Ne
ance of my Wednesday review. I really believe this is something that counsel should be able to work out without court intervention. Thanks, Laura Laura A. Henninger I Partner Haddon, Morgan & Foreman, P.C. 150 1. 10th Avenue I Denver, CO 80203 EFTA00075623 From: Sent: Monday, August 30 20215:42 PM To: Laur
ur review at 500 Pearl in the spring. The HC images come from two sources: First, there were HC images recovered from the CDs seized from Epstein's New York residence. Second, there were HC images and videos recovered from the electronic devices seized from Epstein during his arrest, the search of his Ne
ance of my Wednesday review. I really believe this is something that counsel should be able to work out without court intervention. Thanks, Laura Laura A. Henninger I Partner Haddon, Morgan & Foreman, P.C. 150 1. 10th Avenue I Denver. CO 80203 From: Sent: Monday, Augus To: Laura Menninger (USANYS) Cc: •;
ur review at 500 Pearl in the spring. The HC images come from two sources: First, there were HC images recovered from the CDs seized from Epstein's New York residence. Second, there were HC images and videos recovered from the electronic devices seized from Epstein during his arrest, the search of his Ne
ance of my Wednesday review. I really believe this is something that counsel should be able to work out without court intervention. Thanks, Laura Laura A. Henninger I Partner Haddon, Morgan & Foreman, P.C. 150 I. 10th Avenue I Denver, CO 80203 From: Sent: Monday, Augu To: Laura Menninger • (USANYS) Cc: <
Entities connected to both New York and Laura A. Henninger

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSONLeon Black
PERSONFBI
ORGANIZATION
U.S. Virgin Islands
LOCATION
Michael Cohen
PERSON
Colorado
LOCATIONSouthern District
LOCATION
Denver
LOCATION
Paul Ryan
PERSONJeffrey Pagliuca
PERSONMorgan & Foreman
ORGANIZATION
Bronx
LOCATION
FedEx
ORGANIZATIONBates
PERSONLaura Menninger
PERSON
Pearl
ORGANIZATIONSt. Andrew's
ORGANIZATION
Foreman
PERSON