Epstein Secrets

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

SLEY GROFF and Defendants. No. 17 Civ. 00616 (JGK) MEMORANDUM IN OPPOSITION TO LETTER MOTION TO OPPOSE ALTERNATIVE 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 Morga

filed by an Epstein accuser? The payments coincided with Dershowitz's involvement in the suit. Epstein was not represented by Coffey Burlington. Haddon, Morgan and Foreman P.C. Ghislaine Maxwell 6 587,902 Darren K. Indyke PLLC Haddon represented Maxwell in connection with a lawsuit filed by

87,902 Darren K. Indyke PLLC Haddon represented Maxwell in connection with a lawsuit filed by Epstein accuser 31 Epstein was not represented by Haddon in the suit. 5 Gut. thLink & Rockenbach, P.A. Lesley Groff 19 $5,509,464 Jeffrey Epstein Link & Rockenbach represented Groff and Epstein i

e suit. 5 Gut. thLink & Rockenbach, P.A. Lesley Groff 19 $5,509,464 Jeffrey Epstein Link & Rockenbach represented Groff and Epstein in the Jane Doe 43 lawsuit. It is possible that these payments were made solely for the benefit of Epstein. The transaction dates coincide with the lawsuit. " Se

Y, on the brief), Holland & Knight LLP, Miami, FL, for Intervenors-Appellants Julie Brown and Miami Herald. Ty Gee (Adam Mueller, on the brief), Haddon, Morgan and Foreman, P.C., Denver, CO, for Defendant-Appellee Ghislaine Maxwell. Paul G. Cassell (Sigrid S. McCawley, Boies Schiller Flexner

his victims. In return, prosecutors declined to bring federal charges. Shortly after Epstein entered his plea, two of his victims, proceeding as "Jane Doe 1" and "Jane Doe 2," filed suit against the Government in the Southern District of Florida under the Crime Victims' Rights Act ("CVRA"). The victim

Y, on the brief), Holland & Knight LLP, Miami, FL, for Intervenors-Appellants Julie Brown and Miami Herald. TY GEE (Adam Mueller, on the brief), Haddon, Morgan and Foreman, P.C., Denver, CO, for Defendant-Appellee Ghislaine Maxwell. 3 EFTA00092310 PAUL G. CASSELL (Sigrid S. McCawley, Boies Sch

his victims. In return, prosecutors declined to bring federal charges. Shortly after Epstein entered his plea, two of his victims, proceeding as "Jane Doe 1" and "Jane Doe 2," filed suit against the Government in the Southern District of Florida under the Crime Victims' Rights Act ("CVRA"). The victims

Haddon. Morgan and Foreman, e c Laura A. Menninger II A I> DO N MORGAN FOREMAN April 6. 2016 Via Email ISO East 10th Avenue Denver. Colorado 80203

resent Ghislaine Maxwell in the United States District Court for the Southern District of New York in a defamation action brought by Plaintiff :aka Jane Doe #3). During the course of discovery disputes Ms. Sigrid McCawley, counsel for represented to the Hon. Robert W. Sweet that my client is "under inv

ly 1, 2020 Respectfully submitted, /s/ Laura A. Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) Ty Gee (pro hac vice) Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver. CO 80203 Phone: Fax: Attorneys for Ghislaine Maxwell 21 EFTA00074984 Ca a:Mag0743tikI

ule 21 Motion, the Court shall strike all factual details regarding Jane Doe 3 between the following sentences: "The Government then concealed from Jane Doe #3 the existence of its NPA from Jane Doe 4's proffer is limited to sexual acts between Mr. Epstein and herself. (See DE 280 at 7-8). 5 EFTA00074

$ 182,856 CLAIMS PRESENTED AND ALLOWED BLT NOT PMD None CLAIMS PRESENTED AND REJECTED 47%11111\1T 8/12/19 11/22/19 T&M Protection Services Haddon, Morgan & Foreman PC CONTINGENT AND POSSIBLE CLAIMS See Schedule G 25,030 621,165 $ 646,195 EFTA00075574 SCHEDULE G Civil align. - Lawsuits

2019 Complaint filed on August 20.2019 Complaint Red on August 20, 2019 Complaint filed on August 20.20W EFTA00075575 Civil Claims - lawsuits Jane Doc v. Darren K. Indyke and Richard I). Kahn, in their capacities n the executors of the Estate of Jeffrey It Epstein, Case No. 1:19-ev-08673 (S.I).N.Y)

ding $ 182,856 CLAIMS PRESENTED AND ALLOWED BUT NOT PAID None CLAIMS PRESENTED AND REJECTED \ MOUNT 8/12/19 11/22/19 T&M Protection Services Haddon, Morgan & Foreman PC CONTINGENT AND POSSIBLE CLAIMS See Schedule G 25,030 621,165 646195 EFTA00082479 SCHEDULE G Civil Palme - Lanntuita Ea

the NY Estate of Jeffrey E. Entein, Nine East 71st Street, Corporation. Financial Trust Company, Inc., NES, LIC--Case No.1:19.ev.07625 (S.D.N.Y.) Jane Doe 1 and Jane Doe 2 v. Estate of Jeffrey Epstein et al. Case No. 1:19.cv.7675 NY (S.D.N.Y.) Kadyn Den v. Danen K. Indyke and Richard D. Kahn as Joint Pe

REMAN July 29, 2020 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, P C Ty Gee 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 HI 303.832.2628 www.hmllaw.com [email protected] Re:

ein's "first-known victim" says she was sexually abused by the now-dead pedophile — who called himself her "Godfather" — when she was 13 years old. Jane Doe met Epstein and his friend, Ghislaine Maxwell, in the summer of 1994 at Michigan's interlochen Arts Camp, where she was In voice training, according