Epstein Secrets

edacted, with the 21 exception of Does 1 and 2, Professor Dershowitz, and in 22 deposition testimony already unseale

1 and 2 should 8 be unsealed. 9 Additionally, Alan Dershowitz's name and information 10 identifyin

eir names in this case's documents. Accordingly, 7 the names and identifying information for Does 1 and 2 should 8 be unsealed. 9 Additionally, Alan Dershowitz's name and information 10 identifying him may be unsealed. By his letter at docket entry 11 1138, he has requested that redactions of his name in t

specific comment, personal identifying 20 information for all nonparty Does should be redacted, with the 21 exception of Does 1 and 2, Professor Dershowitz, and in 22 deposition testimony already unsealed by the Court of Appeals. 23 The other names of Does and identifying information 2.1 will remai

ON. LORETTA A. PRESKA, District Judge APPEARANCES BOIES SCHILLER & FLEXNER LLP Attorneys for Plaintiff BY: SIGRID S. McCAWLEY HADDON MORGAN and FOREMAN, P.C. Attorneys for Defendant BY: LAURA A. MENNINGER HOLLAND & KNIGHT Attorneys for Intervenors Julie Brown and Miami Herald Media Company BY:

vidual witnesses with knowledge regarding the facts of this case, yet provided addresses (only of their counsel) as to just two, Jeffrey Epstein and Alan Dershowitz. Plaintiff then also listed categories of witnesses such as "all other then-minor girls, whose identities Plaintiff will attempt to determine" and "

ounsel) as to just two, Jeffrey Epstein and Alan Dershowitz. Plaintiff then also listed categories of witness

heir counsel) as to just two, Jeffrey Epstein and Alan Dershowitz. Plaintiff then also listed categorie

ING DEADLINE TO COMPLETE DEPOSITIONS AND MOTION FOR SANCTIONS FOR VIOLATION OF RULE 45 Laura A. Menninger Jeffrey S. Pagliuca HADDON. MORGAN, AND FOREMAN, P.C. East 10th Avenue Denver, CO 80203 303.831.7364 EFTA00605112 Case 1:15-cv-07433-RWS Document 228 Filed 06/20/16 Page 2 of 29 TABLE OF CON

ntiff in this matter about Harvard Law Professor Alan Dershowitz. Mr. Edwards is counsel for Plaintiff

. Mr. Edwards is a named Plaintiff and Counterclaim Defendant in an action captioned Edwards and Edwards, Plaintiffs and Counterclaim Defendants v. Dershowitz, 15-000072 pending in the Circuit Court in Broward County, Florida. The subject of that litigation includes allegations made by Mr. Edwards during

t of that litigation includes allegations made by Mr. Edwards during his representation of the Plaintiff in this matter about Harvard Law Professor Alan Dershowitz. Mr. Edwards is counsel for Plaintiff in other matters including Plaintiff's attempt to intervene in CVRA litigation pending in the United States D

otection Order to Restrict Mr. Edwards's Access to Information Designated Confidential Laura A. Menninger Jeffrey S. Pagliuca HADDON. MORGAN, AND FOREMAN, P.C. East 10th Avenue Denver, CO 80203 EFTA00595640 Case 1:15-cv-07433-RWS Document 88 Filed 04/08/16 Page 2 of 7 INTRODUCTION Defendant Ghis

. Mr. Edwards is a named Plaintiff and Counterclaim Defendant in an action captioned Edwards and Edwards, Plaintiffs and Counterclaim Defendants v. Dershowitz, 15-000072 pending in the Circuit Court in Broward County, Florida. The subject of that litigation includes allegations made by Mr. Edwards during

t of that litigation includes allegations made by Mr. Edwards during his representation of the Plaintiff in this matter about Harvard Law Professor Alan Dershowitz. Mr. Edwards is counsel for Plaintiff in other matters including Plaintiff's attempt to intervene in CVRA litigation pending in the United States D

ntiff in this matter about Harvard Law Professor Alan Dershowitz. Mr. Edwards is counsel for Plaintiff

otection Order to Restrict Mr. Edwards's Access to Information Designated Confidential Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. East 10th Avenue Denver, CO 80203 EFTA00595633 Case 1:15-cv-07433-RWS Document 88 Filed 04/08/16 Page 2 of 7 INTRODUCTION Defendant Ghisl

cuments responsive to this Request. DOCUMENT REOUEST NO. 11 Produce any documents concerning any of Your attorneys' or agents' communications with Alan Dershowitz's attorneys or agents from 1999 to the present RESPONSE: Ms. Maxwell objects to this Request to the extent it seeks documents or information protecte

ge, the work-product doctrine, the common interest privilege or any other applicable privilege. Defendant is withholding communications between Mr. Dershowitz's counsel and Defendant's counsel which contain work product and concern joint defense or common interest matters. DOCUMENT REOUEST NO. 12 Produce

nt Defense Agreement entered into between You and Alan Dershowitz from 1999 to the present. RESPONSE:

conferral. Dated: May 16, 2016 Respectfully submitted, s/Laura A.Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) AND FOREMAN, P.C. Denver, CO 80203 Phone: Fax: Attorneys for Ghislaine Maxwell 23 EFTA00091375 CERTIFICATE OF SERVICE I certify that on May 16, 2016, I