Epstein Secrets

Case 1:15-cv-07433-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 Co

Case 1:15-cv-07433-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 Respo

0011973 EFTA01734183 Case 1:15-cv-07433-RWS Document 94-1 Filed 04/11/16 Page 2 of 4 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: I 5-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF, VIRGINIA GIUFFRE'S REVISED DISCLOSURE PURSUANT TO FED. R. C

ningerehmflaw.com Defendant in this action. EFTA_R1_00011974 EFTA01734184 Case 1:15-cv-07433-RWS Document 94-1 Filed 04/11/16 Page 3 of 4 iii. Giuffre needs continuing care as a result of the harm she has suffered. Ms. Giuffre was born August 9, 1983 and was 31.4 years old at the beginning of 2015

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

ks any merit, and the Court should deny it. Procedural Background 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 traffickin

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

s were "redundant, immaterial, impertinent, or scandalous." See Doe v. United States, 08-cv-80736 (S.D.Fla.), DE 324 at 4. Ex. F. Specifically as to Jane Doe 3, Judge Marra found her allegations of being "sexually trafficked to several high-profile non-party individuals" to be "lurid" and "unnecessary" to

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