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ll documents reflecting contact with you by any law enforcement or police agency, including any contact by the FBI, Palm Beach Police Department, or West Palm Beach Police Department. DOCUMENT REOUEST NO. 39 All documents reflecting training to fly a helicopter or experience flying a helicopter, including any records concerning
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: [email protected] /s/ Sigrid S. McCawley S
and correct copy of the April 22, 2016 Deposition Transcript of Ghislaine Maxwell. 9. Attached hereto as Exhibit 7, is a true and correct copy of the Palm Beach Police Report. 10. Attached hereto as Exhibit 8, is a true and correct copy of the November 21, 2005 Sworn Statement of 11. Attached hereto as Exhibit 9, is a
GRID STONE McCAWLEY 16 -and- FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 17 BY: BRAD EDWARDS -and- 18 PAUL G. CASSELL 19 HADDON, MORGAN & FOREMAN Attorneys for Defendant 20 BY: LAURA A. MENNINGER JEFF PAGLUICA 21 22 23 24 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00076
correct. The government admits that AUSA received from attorneys, and turned over to AUSA and others in the office, including flight records and Palm Beach Police Department Records. Resp. at 66 & n.2. Both of these documents were produced in discovery in the civil case. 9 EFTA00077584 From any perspective, therefore, AUSA
DENCE OBTAINED FROM THE GOVERNMENT'S SUBPOENA TO BOLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Bobbi C. Stemheim La
Entities connected to both Palm Beach Police Department and MORGAN & FOREMAN

Jeffrey Epstein
PERSON
United States
LOCATIONFBI
ORGANIZATIONthe Southern District
LOCATION
Ghislaine Maxwell
PERSON
Alexander Acosta
PERSONLeon Black
PERSONJack Goldberger
PERSON
Department of Justice
ORGANIZATIONJane Doe
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSON
the United States District Court
ORGANIZATION
Prince Andrew
PERSON
A. Marie Villafana
PERSON
Scarlett Johansson
PERSON
Alfredo Rodriguez
PERSON
Marc Rich
PERSON