Epstein Secrets

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

RNATIVE SERVICE ON MAXWELL Plaintiff, Jane Doe 43, by and through the undersigned counsel, now responds to the letter motion on behalf of non-party Haddon, Morgan and Foreman, P.C. ("Haddon Morgan") requesting that the Court withdraw its order permitting alternative service of defendant Ghislaine Maxw

as entered. However, Haddon Morgan represents only that "had no notice of [the order] until after the Court entered the Order." Mot. at 2. Moreover, Haddon 4 EFTA00792800 Morgan undoubtedly had notice of the order when it received the summons and complaint on October 9, 2017. See Mot. at 1 (acknowle

H A D D O N MORGAN FOREMAN October 4, 2018 Via ECF Hon. John G. Koeltl United States District Judge United States District Court Daniel Patrick Moynihan Courthouse Southern District of New York 500 Pearl Street New

A. MennInger 150 East 10th Avenue Denver, Colorado 80203 PH 303.831/364 DC 303.832.2628 VAVW .hmil ow c o m Imenningergithmflaw.com Dear Judge Koeltl: This is a letter motion requesting a pre-motion discovery conference regarding the need for a protective order pursuant to Fed. R. Civ. P. 26(c)(1

ynihan Courthouse Southern District of New York 500 Pearl Street New York, New York 10007-1312 Re: '. Jeffrey Epstein, et at, 17-cv-00616 (JGK) Haddon, Morgan and Foreman, pc Laura A. MennInger 150 East 10th Avenue Denver, Colorado 80203 PH 303.831/364 DC 303.832.2628 VAVW .hmil ow c o m Imenn

uash. Similar cases in this district demonstrate the "non-standard" nature of the government's conduct regarding these subpoenas. For example, Judge Koeltl observed when considering whether to release a single deposition transcript to the government: "the Second Circuit has made clear that the Governme

Haddon, Morgan and Foreman. P.c Jeffrey Paglluca II A D D O N M OR G A N FOREMAN 303.832.2628 August 24, 2020 VIA EMAIL The Honorable Alison J. Nath