Epstein Secrets

Case 1:17-cv-00616-JGK-SN Document 179 Filed 12/13/18 Page 1 of 14 PAUL G. CASSELL Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah 383 S. University St. Salt Lake Cit

If you have received this message in error, please immediately notify the sender by reply electronic mail and delete the original message. Professor Cassell is admitted to the Utah State Bar. but not the bars of other states. Any views he expresses in this email are his own. From: Laura Menninger Sent:

electronic mail and delete the original message. Professor Cassell is admitted to the Utah State Bar. but not the b

rovide corroborating testimony to Plaintiff as well as destruction of documents and other evidence regarding what they had done." FAC at 65. Judge Koeltl has already recognized the breadth of the allegations in denying a motion to strike a part of the complaint dealing with earlier events. In particul

m [email protected] Bradley J. Edwards EDWARDS POTTINGER LLC 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad @pathtojustice.com Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 [email protected] Michael C. Miller Justin Y.K. Chu Michael A. Keough STEPTOE & JOHNSON,

rdale, FL 33301 brad @pathtojustice.com Paul G. Cassell 383 S. University Street Salt Lake City, UT 841

H A D D O N MORGAN FOREMAN October 4, 2018 Via ECF Hon. John G. Koeltl United States District Judge United States District Court Daniel Patrick Moynihan Courthouse Southern District of New York 500 Pearl Street New

A. MennInger 150 East 10th Avenue Denver, Colorado 80203 PH 303.831/364 DC 303.832.2628 VAVW .hmil ow c o m Imenningergithmflaw.com Dear Judge Koeltl: This is a letter motion requesting a pre-motion discovery conference regarding the need for a protective order pursuant to Fed. R. Civ. P. 26(c)(1

raise the issue of intentional delay with Judge Koeltl. Sincerely, /s/ Sigrid McCawley Sigrid McCawley SM/akc cc: Bradley Edwards (via E-mail) Paul Cassell (via E-mail) Stan Pottinger (via E-mail) EFTA00613862

SM/akc cc: Bradley Edwards (via E-mail) Paul Cassell (via E-mail) Stan Pottinger (via E-mail) EFTA00

ice wherein you state that Jane Doe 43 does not have a basis for alleging jurisdiction in New York. Specifically you stated in your letter to Judge Koeltl as follows: "We respectfully submit that the Plaintiff's Evidence provides grounds for this Court to dispose of the Action entirely, inter alia, un

raise the issue of intentional delay with Judge Koeltl. Sincerely, /s/ Sigrid McCawley Sigrid McCawley SM/akc cc: Bradley Edwards (via E-mail) Paul Cassell (via E-mail) Stan Pottinger (via E-mail) EFTA00792781

SM/akc cc: Bradley Edwards (via E-mail) Paul Cassell (via E-mail) Stan Pottinger (via E-mail) EFTA00

ice wherein you state that Jane Doe 43 does not have a basis for alleging jurisdiction in New York. Specifically you stated in your letter to Judge Koeltl as follows: "We respectfully submit that the Plaintiff's Evidence provides grounds for this Court to dispose of the Action entirely, inter alia, un

of process issues. On November 7, 2017, Mr. Edwards sent the following email: From: Brad Edwards Sent: Tuesday, November 7, 2017 6:51 AM To: Cc Paul Cassell Subject: Maxwell Hi Jeff/Laura, Presumably you have a way of contacting Ms. Maxwell and will do so this week in light of the hearing tomorrow. In

Tuesday, November 7, 2017 6:51 AM To: Cc Paul Cassell Subject: Maxwell Hi Jeff/Laura, Presumably you

to litigate on behalf of defendant Maxwell in this very Court and, thus, presumably has an effective way of communication with Maxwell. This Court (Koeltl, J.), has previously allowed service to be made through an attorney that was representing a client, explaining that the attorney "must know how to c

g by Bradley Edwards External video and Paul G. Cassell meant for inclusion in the Crime Victims Where a

left open what the possible remedy could be.('39) v. Epstein (2015) In a December 2014 Florida court filing by Bradley Edwards External video and Paul G. Cassell meant for inclusion in the Crime Victims Where are they now? The uit,[mo] (then known as biggest players in the Jeffrey , alleged in a sworn

Maxwell has a history of bil achable during legal proceedings.1M198i199}1imi During the lawsuit filed in 2017 from against Maxwell, District Judge John G. Koeltl granted a motion for "alternative service" on the grounds that the plaintiffs efforts to reach Maxwell were persistently thwarted; these included h

Fistos, Lehrman, P.L. 425 N. Andrews Ave., Suite 2 Fort Lauderdale, FL, USA 33301 (954)-524-2820 Fax: (954)-524-2822 Email:[email protected] Paul G Cassell [ATTORNEY TO BE NOTICED] S.J. Quinney College of Law At The University of Utah 383 S. University Street Salt Lake City, UT, USA 84112-0730 (801)-

54)-524-2822 Email:[email protected] Paul G Cassell [ATTORNEY TO BE NOTICED] S.J. Quinney College of

, Lesley Groff; Jeffrey Epstein; Ghislaine Maxwell DOCKET CASE NUMBER: 1:17cv616 FILING DATE: 1/26/2017 JURISDICTION: Federal Question JUDGE: John G. Koeltl NATURE OF SUIT: 890 Other Statutory Actions FILING TYPE: Civil CAUSE: Fed. Question28 USC 1331 JURY DEMAND: Plaintiff PLAINTIFF ATTORNEY(S): Si