Epstein Secrets

v. Indyke, Case No. 19-cv-10475-LGS See, e.g., wants Ghislaine Maxwell to `rot in jail," NY Post (Dec. 4, 2019); Andrew Denney and Bruce Golding, "Jeffrey Epstein's no-bail ruling may encourage more accusers to come forward," NY Post (July 18, 2019) ("McCawley wouldn't identify her new clients but said she enco

ted pleadings involve Plaintiff's effort which were not and should not have been relevant to Plaintiffs false claim that she was sexually abused by Epstein as a minor. The Second Circuit in Brown itself redacted from the summary judgment pleadings and exhibits all of Ms. Maxwell's deposition answers in

o tnsealinu Sealed Materials Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN,

l the questions, lawsuit filed a lawsuit against Mr. Epstein to produce In fact, in connection with her cur

State of New York and admitted to practice in the United States District Court for the Southern District of New York. I am a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell ("Maxwell") in this action. I respectfully submit this declaration in support of Ms. Maxwe

Plaintiff for use at trial and states as follows: I. PLAINTIFF CANNOT SATSIFY THE LEGAL REQUIREMENTS FOR USE OF CERTAIN DEPOSITIONS AT TRIAL A. Jeffrey Epstein and Ronald Rizzo Are Not Unavailable Plaintiff cannot claim that Jeffery Epstein and Ronald Rizzo are "unavailable witnesses" whose testimony can b

testimony, even attempted to serve these witnesses or obtain their attendance at trial. She has now obtained an agreement to accept service by Mr. Epstein's counsel, mooting any claim that he is unavailable.' With respect to Mr. Rizzo, she concedes he resides within 100 miles of the courthouse, and pro

Y PLAINTIFF FOR USE AT TRIAL Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN,

s now obtained an agreement to accept service by Mr. Epstein's counsel, mooting any claim that he is unavailab

State of New York and admitted to practice in the United States District Court for the Southern District of New York. I am a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit this Declaration in support of Ms. Maxwell's Reply t

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JANE DOE 43 Plaintiff, v. JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and Defendants. No. 17 Civ. 00616 (JGK) MEMORANDUM IN OPPOSITION TO LETTER MOTION TO OPPOSE ALTERNATIVE SERVICE

gan attorneys meant to reference some other pleading, as it is true that in the other lawsuit, Ms. had alleged that she was sexually trafficked by Epstein and Maxwell into a London flat associated with Maxwell. But these events took place in around 2001, more than 15 years ago. How service could have

ISTRICT OF NEW YORK JANE DOE 43 Plaintiff, v. JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and De

f Notices of Electronic Filing generated by CM/ECF. Kimo S. Peluso Sher Tremonte, LLP 90 Broad Street, 23nd Floor New York, NY 10004 Counsel for Haddon, Morgan & Foreman, P.C. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Michael C. Mil

correspondence regarding Mr. Brunei's deposition from counsel, Bradley Edwards. 8. Attached as Exhibit G is a Motion to Quash filed by counsel for Jeffrey Epstein in Broward County, Florida in Edwards and Cassell v. Dershoivitz, Case No. 15-0000072 on September 10, 2015. 9. Attached as Exhibit H is a true a

is a Motion to Quash filed by counsel for Jeffrey Epstein in Broward County, Florida in Edwards and Cassel

hibit G is a Motion to Quash filed by counsel for Jeffrey Epstein in Broward County, Florida in Edwards an

State of New York and admitted to practice in the United States District Court for the Southern District of New York. I am a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell ("Maxwell") in this action. I respectfully submit this declaration in support of Defendant

, Defendant. X 15-cv-07433-RWS Declaration Of Jeffrey S. Pagliuca In Support Of Defendant's Motion In

rado 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") in this action. I respectfully submit this declaration in support of the Motio

FBI's New York Office during the 2019 searches of Jeffrey Epstein's residences in New York and the U.S Virgin Isla

w York Office during the 2019 searches of Jeffrey Epstein's residences in New York and the U.S Virgin Isla

FBI's New York Office during the 2019 searches of Jeffrey Epstein's residences in New York and the U.S Vir

w. Would that work? We are generally free thereafter, so please suggest another later time if not. Thank you, Laura Laura A. Henninger I Partner Haddon, Morgan & Foreman, P.C. 150 E. 10th Avenue I Denver, CO 80203 +I 303 831 7364 (Office) Imenninger(Ounflaw.com From: Sent: Tuesday, March 9, 2021 8:36 AM To: Laur