Epstein Secrets

From: " < To: USANYS)" < >, Cc: ' " ' SANYS " Subject: FW: U.S. v. Ghislaine Maxwell, 20 Cr. 330 (MN) -- Objections to Gov't Proposed Redactions in Omnibus Response Date: Tue, 09 Mar 2021 19:00:37 +0000 Attachments: 2021.03.09_LAM_

ed Redactions in Omnibus Response Dear Judge Nathan — Pursuant to Rule 2(B) of the Court's individual rules, attached is a letter setting forth Ms. Maxwell's objections to the redactions proposed by the government to their Omnibus Response and Exhibit 5. Also attached are exhibits setting forth Ms. Max

< >, Cc: ' " ' SANYS " Subject: FW: U.S. v. Ghislaine Maxwell, 20 Cr. 330 (MN) -- Objections to Gov't P

ividual rules, attached is a letter setting forth Ms. Maxwell's objections to the redactions proposed by the g

bit 5. Also attached are exhibits setting forth Ms. Maxwell's proposed redactions. Best regards, Laura A. Menninger Laura A. Menninger I Partner Haddon, Morgan & Foreman, P.C. 150 E. 10th Avenue I Denver, CO 80203 +1 303 831 7364 (Office) EFTA00029843

e.24h24/43134.01FrietibtOrtlefifitin0a0le28013,8111$2eafiabef146f 22 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Reply In Support Of Iler Objections to tnsealinu Sealed Materials Laura A. Menninger Jeffre

iabef146f 22 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Reply In Support Of Iler Objections to tnsealinu Sealed Materials Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C

ine Maxwell says she was Epstein's employee not his madam," MIAMI HERALD (Mar. 18, 2020) (quoting Sigrid McCawley, "It is absolutely appalling that Ghislaine Maxwell, who committed crimes with Epstein against these victims, is seeking to drain funds from the very estate that should be paying the Epstein victims'

ISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Reply In Support Of Iler Objections to tnsealin

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

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 ON MAXWELL

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 ON MAXWELL Plaint

nd As the Court is aware from previous pleadings, this case involves allegations by Jane Doe 43 against powerful and wealthy defendants — including Ghislaine Maxwell — who are alleged to have been running an illegal international sex trafficking organization. For example, as alleged in the complaint, "Defendant

sked Mr. Pagliuca to accept service on behalf of Ms. Maxwell on numerous occasions, both during telephone call

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

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL Defendant. X 15-cv-07433-RWS DEFENDANT'S REPLY IN SUPPORT OF MOTION IN LIMINE TO EXCLUDE IN TOTO CERTAIN DEPOSITIONS DESIGNATED BY PLAIN

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL Defendant. X 15-cv-07433-RWS DEFENDANT'S REPLY IN SUPPORT OF MOTION IN LIMINE TO EXCLUDE IN TOTO CERTAIN DEPOSITIONS DESIGNATED BY PLAINTIFF FOR

Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 EFTA00595612 Defendant Ghislaine Maxwell ("Ms. Maxwell") files her Reply in Support of the Motion in Limine to Exclude In Toto certain depositions designated by Plaintiff for use at trial a

203 EFTA00595612 Defendant Ghislaine Maxwell ("Ms. Maxwell") files her Reply in Support of the Motion in Li

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

Case 1:15-cv-07433-RWS Document 229 Filed 06/20/16 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 1S-cv-07433-RWS Declaration Of Laura A. Menninger In Support Of Defendant's Response in Opposition to Extending Deadline t

he 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's Response in Opposition to Extending Deadline to Complete Depositi

SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 1S-cv-07433-RWS Declaration Of

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

Case 1:15-cv-07433-RWS Document 525 Filed 01/05/17 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-RWS Declaration Of Jeffrey S. Pagliuca In Support Of Defendant's Motion In Limine to Exclude Expert Testimony

t 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 Motion In Limine to Exclude Expert Testimony and Opinion of Pro

istrict 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 Motion In Limine to Exclude Expert Testimony and Opinion of Professor Ter

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

433-RWS Document 94 Filed 04/11/16 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-RWS Declaration Of Laura A. Menninger In Further Support Of Motion To Compel Responses to Defendant's First Se

he 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's Reply In Support of Motion to Compel Responses to Defendant's Fi

t Las Olas Boulevard, Suite 1200 Miami, Florida 33301 Tel: (954) 356-0011 Email: [email protected] Plaintiff- infonnation regarding Defendant, Ghislaine Maxwell's conduct that is the subject of this action 2. Ghislaine Maxwell do Laura A. Menninger, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East le Avenue

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

From: ' < To: '.=1.1116 >< I>, " SUsilYS" (USANYS)" Cc: 'MEr> SANYS" Subject: RE: US v. Maxwell - [Request for 120 or 180-day Adjournment of Trial] Date: Thu, 22 Apr 2021 17:32:25 +0000 Attachments: 2021-04-22_Govtletter_re_GM_requestfor adjou

on for an Adjournment of the trial. Counsel for Ms. Maxwell request redaction of their other clients' names a

ll file either the redacted or unredacted version of this letter on the public docket. Best regards, Laura Menninger Laura A. Menninger I Partner Haddon, Morgan & Foreman, P.C. EFTA00027167 --- PAGE BREAK --- EFTA00027168

From: ' To: '1 (USANYS (USANYS)" Cc: =Mir Subject: RE: US v. Maxwell - [Request for 120 or 180-day Adjournment of Trial] Date: Thu, 22 Apr 2021 20:09:31 +0000 Attachments: 2021-04-22 Gov't letter re GM request_for_ad

on for an Adjournment of the trial. Counsel for Ms. Maxwell request redaction of their other clients' names a

ll file either the redacted or unredacted version of this letter on the public docket. Best regards, Laura Menninger Laura A. Henninger I Partner Haddon, Morgan & Foreman, P.C. EFTA00032784

From: ' To: leMElle." (USANYS)" Subject: RE: US v. Maxwell - 20 Cr. 330 (AJN) - Request to view evidence, highly confidential materials, scenes Date: Tue, 09 Mar 2021 21:01:56 +0000 Inline-Images: image001

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