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UTHERN DISTRICT OF NEW YORK X L. Plaintiff. v. GHISLAINE MAXWELL. Defendant. X 15-cv-07433-RWS Objection to Motion to Appear Pro Hac Vice of Bradley James Edwards or, Alternatively, to Modify the Protection Order to Restrict Mr. Edwards's Access to Information Designated Confidential Laura A. Menninger Jeff
cv-07433-RWS Objection to Motion to Appear Pro Hac Vice of Bradley James Edwards or, Alternatively, to Modify the Protection Order to Restrict Mr. Edwards's Access to Information Designated Confidential Laura A. Menninger Jeffrey S. Pagliuca HADDON. MORGAN, AND FOREMAN, P.C. East 10th Avenue Denver
ed 04/08/16 Page 2 of 7 INTRODUCTION Defendant Ghislaine Maxwell, through her attorneys, objects to the Motion for Admission Pro Hac Vice filed by Bradley Edwards (Doc#86). In the alternative Ms. Maxwell requests that the Court modify the Protective Order, (Doc. # 62) to restrict Mr. Edwards's access to infor
dibility, and (3) there may be an implication that the testifying attorney may be distorting the truth as a result of bias in favor of his client." Ramey v. Dist 141, Int'l Ass 'n of Machinists & Aerospace Workers, 378 F.3d 269, 282-33 (2d Cir.2004). Ms. Maxwell recognizes that Plaintiff may claim th
-07433-RWS Objection to Motion to Appear Pro Hac Vice of Bradley James aim, ards or, Alternatively, to Modify the Protection Order to Restrict Mr. Edwards's Access to Information Designated Confidential Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. East 10th Avenue Denver
ed 04/08/16 Page 2 of 7 INTRODUCTION Defendant Ghislaine Maxwell, through her attorneys, objects to the Motion for Admission Pro Hac Vice filed by Bradley Edwards (Doc#86). In the alternative Ms. Maxwell requests that the Court modify the Protective Order, (Doc. # 62) to restrict Mr. Edwards's access to infor
dibility, and (3) there may be an implication that the testifying attorney may be distorting the truth as a result of bias in favor of his client." Ramey v. Dist 141, Intl Ass'n of Machinists & Aerospace Workers, 378 F.3d 269, 282-33 (2d Cir.2004). Ms. Maxwell recognizes that Plaintiff may claim that
BC News (12/01, Haslett, Bruce), NBC News (12/01, Edwards, Fieldstadt), Fox News (12/01, Betz), CNBC (12/0
associates. Probes by Federal Officials on Phone-hack, Extortion Claims by Jeff Bezos Haven't Led to Public Action The Wall Street Journal (12/01, Ramey, Volz, Viswanatha) reported that in 2019, Amazon founder Jeff Bezos accused the National Enquirer of attempting to extort him with embarrassing text
berov), the Daily Mail (01/04, Laco), and ABC News (01/04, Barr). Attempted Murder Indictment Handed Down In Shooting Of New York Cop Patch (01/04, Edwards) reported that Bryan Martinez was arraigned on an indictment charging him with attempted murder of the off-duty New York Police Department officer.
op FINANCIAL CRIME & CORPORATE SCANDALS Prosecutors Pursue Affinity-Fraud Cases in Which Scammers Target Their Own The Wall Street Journal (01/04, Ramey, Fanelli) reported that the case of stockbroker Mina Tadrus, who has pleaded not guilty, is part of a push by U.S. Attorney Breon Peace in Brooklyn
reported on the story. Continued Reporting: Teddy Roosevelt's Watch, Stolen in 1987, Turns up at Florida Auction House The Washington Post (07/02, Edwards) reported that on Thursday, officials returned a pocket watch engraved with President Theodore Roosevelt's name to Roosevelt's family home at Sagamo
mp's direction. Additional reporting on the story was provided by the New York Times (07/02, Protess, Rashbaum, et al.), Wall Street Journal (07/02, Ramey, Fanelli), Washington Post (07/02, Jacobs, Barrett), CNN (07/02, Reid, Valle, et al.), Washington Times (07/02, Howell Jr.), Washington Examiner (0
, sir. 18 him? 19 Q. Any local reporters from the media here? 19 A. Again, I received a phone call from 20 A. Not that I'm aware of. 20 Mr. Edwards pertaining to a victim that was not in the 21 Q. TV broadcasters looking for news about 21 original report I referred him over to the FBI. 22 M
through Goo& alerts and things he would 12 come across and things I would come across, I would send 13 to him. 14 Q. In other words, Reiter to Ramey, 15 September 6, 2007, 'Channel 5 ran a major story on 16 Epstein at 6:00. Showed footage of Epstein at PBIA and 17 audio of Connolly from Vani
Entities connected to both Bradley Edwards and Ramey

Jeffrey Epstein
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Alan Dershowitz
PERSONMaria Farmer
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONSouthern District
LOCATION
Prince Andrew
PERSONLeon Black
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATION
Donald Trump
PERSON
Department of Justice
ORGANIZATION
Alexander Acosta
PERSONMartin Weinberg
PERSON
Bill Clinton
PERSON
Virginia Giuffre
PERSON
Marc Rich
PERSON