Epstein Secrets

From: ' To: Laura Mennin. er • Bobbi Sternheim Jeff Pagliuca "'BOBBI C STERNHEIM"' , "Mark S. Cohen" Cc: 1=pleMIE> USANYS " Subject: RE: US v. Maxwell, 20 Cr. 330 (AJN) - meet and confer Date: Thu, 29 Apr 2021 23:00:26 +0000 Attachments: 2021-04-30_Govit_Letter_to_Manleyidraft_to_defense).pdf Cou

s and then you are to write the Court by Friday. I am free tomorrow afternoon to discuss if you wish. Thanks, Laura Laura A. Henninger I Partner Haddon, Morgan & Foreman, P.C. From: < Sent: Tuesday, April 27, 2021 10:22 PM EFTA00029138 --- PAGE BREAK --- To: 8obbi Sternheim ;'8O681 C STERNHEIM' < s; Laura Menning

he State of New York and admitted to practice in the United States District Court for the Southern District of New York. Iam 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 Response in Opp

ons with her, which he denies. Ms Roberts claims are obvious lies and should be treated as such and not publicised as news, as they are defamatory. Ghislaine Maxwell's original response to the lies and defamatory claims remains the same. Maxwell strongly denies allegations of an unsavoury nature, which have appeared

lying in a hammock.‘We all dined together that night. Jeffrey was at the head of the table. Bill was at his left. | sat across from him. Emmy Tayler, Ghislaine’s blonde British assistant, sat at my right. ‘Ghislaine was at Bill’s left and at the left of Ghislaine there were two olive-skinned brunettes who'd

ell - Cohen & Gresser LLP ([email protected])" <[email protected]>, 'BOBBI C STERNHEIM' <[email protected]> Subject: RE: US v. Maxwell - 20 Cr. 330 (MN) - Request to view evidence, highly confidential materials, scenes Date: Wed, 07 Apr 2021 16:05:44 +0000 Attachments: New_York_Ev

ed this morning that the Marshals intend to bring Ms. Maxwell back to the MDC each review day at 4:30pm. So we

s scheduled on April 12 and continue day to day until we are finished, with a break if necessary for the arraignment. Laura A. Menninger I Partner Haddon, Morgan & Foreman, P.C. 150 E. 10th Avenue I Denver, CO 80203 +1 303 831 7364 (Office) [email protected] From: Sent: Saturday, March 27, 2021 4:38 PM To: Laura Men

ca <[email protected]>, "Christian R Everdell - Cohen & Gresser LLP (ceverdell@cohengressercom)" <ceverdell®cohengressencotn> Subject: RE: US v. Maxwell - 20 Cr. 330 (MN) - Request to view evidence, highly confidential materials, scenes Date: Sat, 10 Apr 2021 00:42:33 +0000 Attachments: 2021.04.09_

ed this morning that the Marshals intend to bring Ms. Maxwell back to the MDC each review day at 4:30pm. So we

let us know if you will not agree to any of these steps so that we can address the issues with the Court. Thank you. Laura A. Menninger I Partner Haddon, Morgan & Foreman, P.C. 150 E. 10th Avenue I Denver, CO 80203 +I 303 831 7364 (Office) Imenninger(anflaw.com From: Sent: Tuesday, March 16, 2021 4:40 PM To: Laura Menn

working with our paralegals to look into your requests below. Our paralegals are also still working on the list of files that you provided that Ms. Maxwell has been unable to review at the MDC. As soon as we are able to provide an update on these issues, I will reach back out. Best, Assistant United S

king on the list of files that you provided that Ms. Maxwell has been unable to review at the MDC. As soon as

iles which might indicate file creation/modified dates Please let me know if you have any questions. Thanks, Laura Laura A. Menninger I Partner Haddon, Morgan & Foreman, P.C. From: Sent: Friday, April 23, 2021 10:30 AM To: Christian Everdell (USANYS) Cc: Jeff Pagliuca (Office) < < < Subject: RE: Discovery Issues