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n. See Complaint at 9¶ 9-10. The Edwards and Epstein lawsuit also appears to still have a portion of the case on appeal. See Edwards v. Epstein and Scott Rothstein (Mr. Edwards' former law partner), District Court of Appeal of Florida, Fourth District, No. 4D14-2282. This Court advised the pro hac vice applica
case on appeal. See Edwards v. Epstein and Scott Rothstein (Mr. Edwards' former law partner), District Court
hac vice by these applicants. Dated: April 21, 2016. EFTA00605451 Respectfully submitted, /s/ Laura A. Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca HADDON, MORGAN AND FOREMAN, P.C. 150 East 10ih Avenue Denver, CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 [email protected] Attorneys
nninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca HADDON, MORGAN AND FOREMAN, P.C. 150 East 10ih
ase 20-2413, Document 44. 08/20/2020, 2913556, Page58 of 78 App.-0832 28 G4LMGIUC 1 another case, as I understand it, Edwards v. Epstein and 2 Rothstein, which is also pending. I can confer about this, 3 your Honor. 4 THE COURT: Let's do this. When do you plan to return 5 to the snow fields? 6
20, denying Ms. Maxwell's motion to reconsider. Dated: July 29, 2020. Respectfully submitted, s/ Laura A. Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) Ty Gee (pro hac vice) HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Ghislaine Maxwell 1 EFTA00076389 CasastrabiAZI71432)IaAini
Sorry. No. 6 Thanks very much. 7 MR. CASSELL: Thank you, your Honor. 8 THE COURT: Anything from the defense. 9 MR. PAGLIUCA: Yes, your Honor. Jeff Pagliuca on 10 behalf of Ms. Maxwell. 11 Your Honor, I have never opposed a pro hac motion in 12 my 34 years of practice, so this is a first for me. But
23 24 25 Case 20-2413, Document 44, 08/20/2020, 2913556, Page67 of 78 K7N9GIUD App.-0841 150. Declaration of Mister how does he say it, Mr. Pagliuca? Say it again. MS. MENNINGER: Pagliuca. THE COURT: Mr. Pagliuca in opposition to the motion to compel. Unseal. 150-1. Additional pages from Ms. M
teresting additional details that can be 11 used in the letter to the mail and in the following press 12 complaints. In addition, this article on Rothstein you may 13 find helpful. 14 "What is the number one lie that Ms. Maxwell points 15 to? Number 1. Bill Clinton identified in lawsuit against his
D FOREMAN, P.C. Attorneys for Defendant 20 BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. 21 22 23 24 25 SO
P.C. Attorneys for Defendant 20 BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. 21 22 23 24
s and interesting additional details that can be used in the letter to the mail and in the following press complaints. In addition, this article on Rothstein you may find helpful. "What is the number one lie that Ms. Maxwell points to? Number 1. Bill Clinton identified in lawsuit against his former fri
N AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRICT REPO
AN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRIC
0800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually,
E CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE No.502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN Wednesday, March 17,
er. Q. Okay. Do you remember the photographs? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Not
s and interesting additional details that can be used in the letter to the mail and in the following press complaints. In addition, this article on Rothstein you may find helpful. "What is the number one lie that Ms. Maxwell points to? Number 1. Bill Clinton identified in lawsuit against his former fri
GAN AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRICT R (2
EMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRICT
them, in securing their testimony or requiring 10 them to cooperate in any sense. 11 I cite to the Court the case of Coquina Investments v. 12 Rothstein, which I didn't realize until I was reading this last 13 night is ironic because the defendant in the Rothstein case is 14 Mr. Edwards' former pa
ly, your Honor, I think you can 10 just see from the upset there what's going to be happening at 11 this trial. This is the direct quote from Mr. Pagliuca. 12 "Fantastical conspiracy". That's going to be the argument from 13 the other side. They're obviously entitled to advance that 14 argument. B
control over them, in securing their testimony or requiring them to cooperate in any sense. I cite to the Court the case of Coquina Investments v. Rothstein, which I didn't realize until I was reading this last night is ironic because the defendant in the Rothstein case is Mr. Edwards' former partner, w
ly, your Honor, I think you can 10 just see from the upset there what's going to be happening at 11 this trial. This is the direct quote from Mr. Pagliuca. 12 "Fantastical conspiracy". That's going to be the argument from 13 the other side. They're obviously entitled to advance that 14 argument. B
control over them, in securing their testimony or requiring them to cooperate in any sense. I cite to the Court the case of Coquina Investments v. Rothstein, which I didn't realize until I was reading this last night is ironic because the defendant in the Rothstein case is Mr. Edwards' former partner, w
: In reply, your Honor, I think you can just see from the upset there what's going to be happening at this trial. This is the direct quote from Mr. Pagliuca. "Fantastical conspiracy". That's going to be the argument from the other side. They're obviously entitled to advance that argument. But that's wh
Sorry. No. 6 Thanks very much. 7 MR. CASSELL: Thank you, your Honor. 8 THE COURT: Anything from the defense. 9 MR. PAGLIUCA: Yes, your Honor. Jeff Pagliuca on 10 behalf of Ms. Maxwell. 11 Your Honor, I have never opposed a pro hac motion in 12 my 34 years of practice, so this is a first for me. But
Page: EFTA00028854 →DISTRICT REPORTERS, P.C. EFTA00028877 --- PAGE BREAK --- App.-0832 28 G4LMGIUC 1 another case, as I understand it, Edwards v. Epstein and 2 Rothstein, which is also pending. I can confer about this, 3 your Honor. 4 THE COURT: Let's do this. When do you plan to return 5 to the snow fields? 6
Page: EFTA00028878 →Entities connected to both Scott Rothstein and Jeffrey Pagliuca

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Ghislaine Maxwell
PERSONJack Goldberger
PERSONLaura Menninger
PERSONJack Scarola
PERSON
Michael Cohen
PERSON
Prince Andrew
PERSONJane Doe
PERSON
George W. Bush
PERSONSouthern District
LOCATIONMaria Farmer
PERSON
Denver
LOCATION
Paul Cassell
PERSON
Alan Dershowitz
PERSON
Kenneth Marra
PERSON
United States
LOCATION
Donald Trump
PERSONSpencer Kuvin
PERSON
Salt Lake City
LOCATION