Epstein Secrets

r a protective order pursuant to Fed. R. Civ. P. 26(c)(1) and Local Civ. R. 26.4(a) concerning the date and location of the deposition of Defendant Ghislaine Maxwell. Counsel has conferred in good faith with Plaintiffs counsel by phone and by email and has not been able to otherwise resolve the dispute. The Rul

ous depositions.' No response to that proposal was received. By email of September 4, undersigned counsel proposed dates of October 9 or 10 for Ms. Maxwell's deposition. Again, Plaintiff failed to respond. Yet, on September 26, without conferring regarding availability and ignoring the dates previously

date and location of the deposition of Defendant Ghislaine Maxwell. Counsel has conferred in good faith wit

ned counsel proposed dates of October 9 or 10 for Ms. Maxwell's deposition. Again, Plaintiff failed to respond

H A D D O N MORGAN FOREMAN October 4, 2018 Via ECF Hon. John G. Koeltl United States District Judge United States District Court Daniel Patrick Moynihan Courthouse Southern District of New York 500 Pearl Street New York, New York 10007-1312 Re: '. Jeffrey Epstein, et at, 17-cv-00616 (JGK) Haddon, Morgan an

312 Haddon. Morgan and semen, Affray S. Pognuca 130 East KM Avernus Denver. Colorado 80203 303.831.7364 n 303 832.2 r-• - • crap 4s: Re: v, Maxwell. 15-ev-07433-RWS Dear Judge Sweet: I am writing to request the Court to extend the deposition deadline of Plaintiff's designated expert Dianne Flo

ecember 29, 2016 to January 5, 2017. Counsel for Ms. Maxwell was unable to complete this deposition by the pre

DGE SWEET CHAMBERS December 29, 2016 Via Facsimile O1211105-7925 Hon. Robert W. Sweet United States District Judge United States District Court Daniel Patrick Moynihan Courthouse Southern District of New York 500 Pearl Street, Room 1940 New York, New York 10007-1312 Haddon. Morgan and semen, Affray S. Pognuca 130 East KM

Court Daniel Patrick Moynihan Courthouse Southern District of New York 500 Pearl Street, Room 1940 New York, New York 10007-1312 Re: Giqffie v. Maxwell, Case No.: 15-ev-07433-RWS Dear Judge Sweet: This is an unopposed letter motion for an extension of time in which Ms. Giuffre requests to file a

grid McCawley, Esq. [email protected] VIA ECF March 17, 2017 Hon. Robert W. Sweet United States District Judge United States District Court Daniel Patrick Moynihan Courthouse Southern District of New York 500 Pearl Street, Room 1940 New York, New York 10007-1312 Re: Giqffie v. Maxwell, Case No.: 15-ev-07433-RWS Dear