Epstein Secrets

E OF LAW, UNIVERSITY OF UTAH,' 383 University Street, Salt Lake City, UT 84112, By: Paul G. Cassell, Esq. Counsel for Defendant Ghislaine Maxwell: HADDON, MORGAN AND FOREMAN, P.C., 150 East 10th Avenue, Denver, CO 80203, By: Laura A. Menninger, Esq., Jeffrey S. Pagliuca, Esq., Ty Gee, Esq. Counsel for Intervenor Michael Cemo

dential with the Court, it was to additionally file a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. Id. ¶ 10. Absent consent of the producing party, designated documents "shall not ... be disclosed."3 Id. 115 . WESTLAW 2018 Thomson Reuters. No c

, and trade secrets). Ms. Maxwell is aware, based on publicly reported statements by Plaintiff, Plaintiff's counsel, the United States Attorney for the Southern District of New York, and the Attorney General for the U.S. Virgin Islands, that investigations surrounding the alleged conduct of Mr. Epstein survive his death. It is

10, 2020. Respectfully submitted, /s/Jeffrey S. Pagliuca 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: 303.831.7364 Fax: 303.832.2628 [email protected] Attorneys for Ghislaine Maxwell " The follo

K Yes K No Do you or does any member of your family or a close friend personally know or have past or present dealings with the U.S. Attorney for the Southern District of New York, Damian Williams, or anyone else who works for or used to work for the U.S. Attorney's Office for the Southern District of New York? K Yes K No 3

f the defense attorneys or law firms who are representing the Defendant: Christian Everdell of Cohen & Gresser LLP a Yes K No Jeffrey Pagliuca of Haddon, Morgan and Foreman, P.C. a Yes K No Laura Menninger of Haddon, Morgan and Foreman, P.C. K Yes o No Bobbi Stemheim of Law Offices of Bobbi C. Stemheim a Yes K No 321 Do yo