Epstein Secrets

Case 1:15-cv-07433-RWS Document 422 Filed 09/06/16 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S RENEWED MOTION TO COMPEL SETTLEMENT AGREEMENT Laura A.

Case 1:15-cv-07433-RWS Document 422 Filed 09/06/16 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S RENEWED MOTION TO COMPEL SETTLEMENT AGREEMENT Laura A. Menninger

attorneys for You and/or Mr. Epstein." Menninger Decl. Ex. A. • On March 16, 2016 Defendants responded to the Request for production stating "Ms. Giuffre is in possession of a document that contains a confidentiality provision. If Defendant obtains, and produces to Ms. Giuffre, a written waiver from .

DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant.

fendant. X 15-cv-07433-RWS DEFENDANT'S RENEWED MOTION TO COMPEL SETTLEMENT AGREEMENT Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. 150 East 10i° Avenue Denver, CO 80203 303.831.7364 EFTA_R1_00013286 EFTA01734801 Case 1:15-cv-07433-RWS Document 422 Filed 09/06/16 Page

ts of New York, I BRADLEY J. EDWARDS, hereby move this Court for an Order for admission to practice Pro Hac Vice to appear as counsel for Plaintiff, VIRGINIA L. GIUFFRE, in the above-captioned action. 1 am in good standing of the bar(s) of the state(s) of Florida and there are no pending disciplinary proceedings ag

COURT SOUTHERN DISTRICT OF NEW YORK Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghis

ES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RW

all counsel of record listed below through the ECF system. SERVICE LIST Laura A. Menninger Jeffrey S. Pagliuca (Pro Hac Vice) HADDON MORGAN AND FOREMAN 150 East 10th Avenue Denver, CO 80203 Telephone: (303)-831-7364 Fax: (303)-832-2628 Email: [email protected] Email: [email protected] A

ly 20 years old. Epstein did not like her and did not want her brought again. Rivera added that Marsh was a heavy drug user. Miller also introduced Virginia Last Name Unknown (LNU), aka Jenny to Epstein. Virginia LNU was younger than Rivera and visited Epstein's residence one time. Virginia LNU had a S

. WILD stated that one of the girls she stayed with on occasion, AMY FOREMAN, also started providing EPSTEIN with massages. A telephone number for FOREMAN was (561)718-1924. WILD said that her family resides in Wellington, Florida, possibly Crestwood. WILD also stayed with JACLYN REGOLI during this sa

ly 20 years old. Epstein did not like her and did not want her brought again. Rivera added that Marsh was a heavy drug user. Miller also introduced Virginia Last Name Unknown (LNU), aka Jenny to Epstein. Virginia LNU was younger than Rivera and visited Epstein's residence one time. Virginia LNU had a S

. WILD stated that one of the girls she stayed with on occasion, AMY FOREMAN, also started providing EPSTEIN with massages. A telephone number for FOREMAN was (561)718-1924. WILD said that her family resides in Wellington, Florida, possibly Crestwood. WILD also stayed with JACLYN REGOLI during this sa