Epstein Secrets

XNER LLP 15 Attorneys for Plaintiff BY: SIGRID STONE McCAWLEY 16 -and- FARMER, JAFFE, WEISSING, EDWA

20, denying Ms. Maxwell's motion to reconsider. Dated: July 29, 2020. Respectfully submitted, s/ Laura A. Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) Ty Gee (pro hac vice) HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Ghislaine Maxwell 1 EFTA00076389 CasastrabiAZI71432)IaAini

Sorry. No. 6 Thanks very much. 7 MR. CASSELL: Thank you, your Honor. 8 THE COURT: Anything from the defense. 9 MR. PAGLIUCA: Yes, your Honor. Jeff Pagliuca on 10 behalf of Ms. Maxwell. 11 Your Honor, I have never opposed a pro hac motion in 12 my 34 years of practice, so this is a first for me. But

23 24 25 Case 20-2413, Document 44, 08/20/2020, 2913556, Page67 of 78 K7N9GIUD App.-0841 150. Declaration of Mister how does he say it, Mr. Pagliuca? Say it again. MS. MENNINGER: Pagliuca. THE COURT: Mr. Pagliuca in opposition to the motion to compel. Unseal. 150-1. Additional pages from Ms. M

his enemies." Trump's decision to commute Roger Stone's prison sentence and "the Department of Justice

her sex crimes case to impose a gag order on lawyers and others to reduce prejudicial pretrial publicity and protect her chances of a fair trial." Jeffrey Pagliuca "filed a letter in Manhattan federal court citing public comments made by Acting U.S. Attorney Audrey Strauss, the head of New York's FBI office and

nd protect her chances of a fair trial." Jeffrey Pagliuca "filed a letter in Manhattan federal court citing

his enemies." Trump's decision to commute Roger Stone's prison sentence and "the Department of Justice

r her sex crimes case to impose a gag order on lawyers and others to reduce prejudicial pretrial publicity and protect her chances of a fair trial." Jeffrey Pagliuca "filed a letter in Manhattan federal court citing public comments made by Acting U.S. Attorney Audrey Strauss, the head of New York's FBI office an

and protect her chances of a fair trial." Jeffrey Pagliuca "filed a letter in Manhattan federal court citin

19 Perfect Pearl Co., Inc. v. Majestic Pearl & Stone, Inc., 889 F. Supp. 2d 453, 457 (S.D.N.Y. 2012)

EMORANDUM OF LAW IN OPPOSITION TO EXTENDING DEADLINE TO COMPLETE DEPOSITIONS AND MOTION FOR SANCTIONS FOR VIOLATION OF RULE 45 Laura A. Menninger Jeffrey S. Pagliuca HADDON. MORGAN, AND FOREMAN, P.C. East 10th Avenue Denver, CO 80203 303.831.7364 EFTA00605112 Case 1:15-cv-07433-RWS Document 228 Filed 06/20/

LATION OF RULE 45 Laura A. Menninger Jeffrey S. Pagliuca HADDON. MORGAN, AND FOREMAN, P.C. East 10th Ave

his enemies." Trump's decision to commute Roger Stone's prison sentence and "the Department of Justice

her sex crimes case to impose a gag order on lawyers and others to reduce prejudicial pretrial publicity and protect her chances of a fair trial." Jeffrey Pagliuca "filed a letter in Manhattan federal court citing public comments made by Acting U.S. Attorney Audrey Strauss, the head of New York's FBI office and

nd protect her chances of a fair trial." Jeffrey Pagliuca "filed a letter in Manhattan federal court citing

ess — he said earlier this year that he did not think Miller would be called — but confirmed that Miller plans to comply." The result is that one of Stone's closest aides "will be testifying about him at his trial in November for lying to Congress about his dealings with WikiLeaks during the 2016 elect

uld unfairly damage their reputations' Jeffrey S. Pagliuca, an attorney involved in the litigation, "said th

d a judge not to release his name or the names of others accused in the documents of wrongdoing, arguing it could unfairly damage their reputations' Jeffrey S. Pagliuca, an attorney involved in the litigation, "said the people are named in 29 depositions, voluminous investigatory records and an 'address book' that i

his enemies." Trump's decision to commute Roger Stone's prison sentence and "the Department of Justice

her sex crimes case to impose a gag order on lawyers and others to reduce prejudicial pretrial publicity and protect her chances of a fair trial." Jeffrey Pagliuca "filed a letter in Manhattan federal court citing public comments made by Acting U.S. Attorney Audrey Strauss, the head of New York's FBI office and

nd protect her chances of a fair trial." Jeffrey Pagliuca "filed a letter in Manhattan federal court citing

wos" (4 anmumeares rf oe é yO iA 2992 e nae ae Stone se irs Fi cz 2 BIg Biapeyoo BOUDA JO UIOD"}O2D)

ment is being served to all parties of record via transmission of the Electronic Court Filing System generated by CM/ECF. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Sigrid S. ne HOUSE_OVERSIGHT_014121 EXHIBIT 1 HOUSE_OVERSIGHT_0

ted by CM/ECF. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10

ara Stocking Paul Stoffels Wilfried Stoll Greg Stone Max Stone Barry Stowe Kim Stratton Ofra Strau

aasschen Gregory R. Page Reed Paget Stephen G. Pagliuca Dinesh C. Paliwal Mark Palmer Marco Panara Vi

toffels Wilfried Stoll Jens Stoltenberg Carole Stone Barry Stowe Angela Strank Ivan Streshinsky Br

University of Reading United Kingdom Stephen G. Pagliuca Managing Director Bain Capital USA Scott Paint