Epstein Secrets

5 I. PLAINTIFF'S LACK OF DILIGENCE 6 6 B. Ross Gow 9 C. Jean Luc Brunel 10 D. Jeffrey Epstei

. For example, Plaintiff issued a 12 McCawley Decl. in Support of Request to Exceed Ten Deposition Limit, Exhibit I (Doc. # 173.1) at 28 (Letter of Menninger to McCawley (Feb. 25, 2015) ("I would suggest that rather than repeated entails on the topic of scheduling the various depositions in this case, or

FENDANT'S COMBINED MEMORANDUM OF LAW IN OPPOSITION TO EXTENDING 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 Docu

en Epstein brought her from Yugoslavia to live with him. Several victims told police that she was involved in orgies with Epstein and underage girls. Ross, Groff and Kellen, now known by her married name, Vickers, were schedulers who arranged his underage sex sessions, according to the FBI and police.

ands of dollars from British tabloids with a motive for selling papers and advertisements and without regard for truth, veracity or substantiation,” Menninger noted in a 2016 response filed in the case. In February, the Miami Herald filed a federal court motion in the Southern District of New York, seeking

, Jeffrey Epstein manipulated the system | Miami Herald Page 14 of 17 Case 1:19-cv-03377 Document 1-1 Filed 04/16/19 Page 15 of 18 Maxwell’s lawyer, Laura Menninger, declined to comment, referring the Herald to the court history. wy! 4 g ry “{Roberts] fabricated a story of abuse at the hands of Ms. Maxwell in ex

A00792761 Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is o no

nted by the Plaintiff in her case in chief, Ms. Maxwell may offer testimony from the following witnesses at trial: 1. Ghislaine Maxwell (live) c/o Laura A. Menninger, Esq. Haddon, Morgan & Foreman, P.C. 150 E. 10th Ave. Denver, CO 80203 2. Kathy Alexander (live) Michaelhouse Pvt Bag X1 Balgowan KwaZulu-Natal 3

A00617401 Thanks for your understanding. Best Ross Ross Gow ACUITY Reputation Jane Doe 3 is so n

ented by the Plaintiff in her case in chief, Ms. Maxwell may offer testimony from the following witnesses at trial: 1. Ghislaine Maxwell (live) do Laura A. Menninger, Esq. Haddon, Morgan & Foreman, P.C. 150 E. 10th Ave. Denver, CO 80203 2. Kathy (live) 3. Miles (live) 4. Philip Barden (live) Devonshires So

documents relating to communications with you and Ross Gow from 2005 — present. DOCUMENT REQUEST NO. 18

tached document PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS To DEFENDANT OHISLAINE MAXWELL via Email to the following counsel of record. Laura A. Menninger, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10m Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: Imenninger@hmfla

ssed, Rodriguez suggested he used a Taser on Fanone to keep him from getting more seriously injured. ABC News (12/01, Barr), The Daily Beast (12/01, Ross), and CNN (12/01, Polanz, Lybrand, Rabinowitz) also reported on the story. Charges Filed Against Rhode Island Man Accused of Using Table Leg as Clu

ic detail on Tuesday about the alleged encounters in the 1990s, portraying Maxwell as an active participant. The article noted that defense attorney Laura Menninger confronted the woman with FBI documents from 2019 and 2020, saying she had told the government her memory was foggy on whether Maxwell was present

n District and elsewhere" by Ms. Maxwell's agent, Ross Gow, (Comp!. 11 29, 30, 32), but attaches a 2011

Dismiss. 10 EFTA00591588 Case 1:15-cv-07433-RWS Document 25 Filed 12/28/15 Page 13 of 13 Dated: December 28. 2015. Respectfully submitted, s/ Laura A. Menninger Laura A. Menninger (LM-1374) HADDON, MORGAN AND FOREMAN, P.C. East 10th Avenue Denver, CO 80203 Phone: Fax: Attorneys for Ghislaine Maxwell CER

WER: 2. Identify any action that you took after Ross Gow issued the January 2015 statement regarding

ect copy of the above and foregoing has been provided by electronic mail to all counsel of record identified below, on this 26th day of May, 2016. Laura A. Menninger, Esq. Jeffrey S. Pagliuca„ Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: Fax: Email: Email: By: Is/ S

dentities of the individual(s) or entities paying Ross Gow, or any entities associated with Ross Gow, f

ve for a Protective Order with regard to this Request, without further 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

rra/Johnson (S.D. Fla. Jan. 2, 2015) EXHIBIT N: Ross Gow Email re. statement on behalf of Ghislaine Ma

e Court dismiss Counts Five and Six. Dated: March 15, 2021 10 EFTA00097391 Respectfully submitted, s/ Jeffrey S. Pagliuca Jeffrey S. Pagliuca Laura A. Menninger HADDON MORGAN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine