Epstein Secrets

are as follows: 1. I am an attorney at law duly licensed in the State of Colorado and admitted to practice in the United States District Court for the Southern District of New York pro hac vice. I am a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell ("Maxwell

pert Testimony and Opinion of Professor Terry Coonan, J.D. I. Jeffrey S. Pagliuca, declare as follows: 1. I am an attorney at law duly licensed in the State of Colorado and admitted to practice in the United States District Court for the Southern District of New York pro hac vice. I am a member of the law firm Hadd

s Court has personal jurisdiction over Maxwell. Maxwell resides in New York City, and this action arose, and defamatory statements were made, within the Southern District of New York. 5. Venue is proper in this Court as the cause of action arose within the jurisdiction of this Court. 2 EFTA00676991 Case 1:15-cv

his Court. 2 EFTA00676991 Case 1:15-cv-07433 Document 1 Filed 09/21/15 Page 3 of 12 PARTIES. 6. Plaintiff is an individual who is a citizen of the State of Colorado. 7. Defendant Maxwell, who is domiciled in the Southern District of New York, is not a citizen of the state of Colorado. FACTUAL ALLEGATIONS 8.

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is true—and that they were in fact true. Pursuant to the stipulated order entered by this Court on March 20, 2015 that appointed a Commissioner in the State of Colorado, Dershowitz served a subpoena for the production of documents and a videotaped deposition on Jane Doe No. 3. See Exhibit G.2. The subpoena seeks, a

ole in negotiating the NPA on Epstein's behalf. Indeed, Dershowitz helped negotiate an agreement that provided immunity from federal prosecution in the Southern District of Florida not only to Epstein, but also to "any potential coconspirators of Epstein." NPA at 5. Thus, Dershowitz helped negotiate an agreement wit

founded pleading." Exhibit A, Compl. 17. Pursuant to the stipulated order entered by this Court on March 20, 2015 that appointed a Commissioner in the State of Colorado, Dershowitz served a subpoena for the production of documents and a videotaped deposition on Jane Doe No. 3. See Exhibit G.2 The subpoena seeks, am