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Avenue Denver, Colorado 80203 PH 303.831.7364 HI 303.832.2628 www.hmllaw.com [email protected] Re: Reconsideration of the Court's July 23 Ruling Giuffie v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its Protect
baby: Virginia Roberts March 22.2020 I 3:24pm Virginia Roberts Giuffre wham Farrington Former teen "sex slave" when t
18/20 EFTA00075105 Cas63sE 941143 VI/0Rn @Want rtit7100V2 CFM2ft 057233/2 G g gatjef tv 013161 Epstein, Maxwell wanted me to have surrogate baby: Virginia Roberts March 22.2020 I 3:24pm Virginia Roberts Giuffre wham Farrington Former teen "sex slave" when they asked her, at g , pear mew sur MUM
it7100V2 CFM2ft 057233/2 G g gatjef tv 013161 Epstein, Maxwell wanted me to have surrogate baby: Virginia Roberts March 22.2020 I 3:24pm Virginia Roberts Giuffre wham Farrington Former teen "sex slave" when they asked her, at g , pear mew sur MUM says she finally fled Jeffrey Epstein and Ghislaine Maxwe
k for Epstein can be found in excerpts -- unsealed by a federal court last year -- of two 2016 depositions related to a defamation lawsuit filed by Virginia Giuffre. one of Epstein's alleged victims, who has accused Maxwell of recruiting her into Epstein's alleged child trafficking scheme, an accusation Maxwell
baby: Virginia Roberts March 22.2020 I 3:24pm Virginia Roberts Giuffre wham Farrington Former teen "sex slave"
cc: U.S. Attorney's Office for the Southern District of New York Mark Cohen Christian Everdell Cohen & Gresser LLP Laura A. Menninger Haddon, Morgan & Foreman, P.C. EFTA00075071 Cagesle120o140ZaUX.PertDo&Aflt."1016ZO. PEIR603824/20e1a4e205f 2 EXHIBIT B EFTA00075072 Cagaltellnatt0WICS30A(MIDgisticerAW
ly published: The basis for Ms. defamation claim is a January 2, 2016 press statement issued by Defendant to the international press as follows: "Jane Doe 3 is Victoria Roberts — so not a new individual. The allegations made by against Ghislaine Maxwell are untrue. The original allegations are not new a
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 3275 South Africa 3. Miles Alexa
ly published: The basis for Ms. defamation claim is a January 2, 2016 press statement issued by Defendant to the international press as follows: "Jane Doe 3 is — so not a new individual. The allegations made by against Ghislaine Maxwell are untrue. The original allegations are not new and have been ful
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 Solicitors LLP 30 Finsbury Circus
Entities connected to both Virginia Giuffre and Morgan & Foreman

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
United States
LOCATION
Alan Dershowitz
PERSONLeon Black
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
New York
LOCATIONthe Southern District
LOCATION
Colorado
LOCATIONMaria Farmer
PERSON
Michael Cohen
PERSONFBI
ORGANIZATION
Denver
LOCATION
Paul Cassell
PERSON
Bloomberg L.P.
ORGANIZATION
George Mitchell
PERSON
Alfredo Rodriguez
PERSON