Epstein Secrets

Schiller & Flexner LLP OPPOSING ATTORNEY: Sigrid McCawley Court- Judge/ Agency appealed from: Hon. Lorett

l's guilt. For example, Bradley Edwards opined that Ms. Maxwell was "a main facilitator" of Epstein's crimes who "started the whole thing." Id. And Sigrid McCawley praised the prosecutors: "[They] have done an incredible job and they're being very meticulous, they want to make sure that the Indictments stick.

r [name of attorney, with fon, address, phone number and e-mail) Haddon, Morgan and Foreman, P.C. Boies Schiller & Flexner LLP OPPOSING ATTORNEY: Sigrid McCawley Court- Judge/ Agency appealed from: Hon. Loretta A. Preska, District Judge (S.D.N.Y.) Please check appropriate boxes: Has movant notifiedr oposin

7) 13 Hunt v. Enzo Biochem, Inc., 904 F. Supp. 2d 337 (S.D.N.Y. 2012) 12 In re Long Island Lighting Co., 129 F.3d 268 (2d Cir. 1997) 15 In re New York Times Co., 828 F.2d 110 (2d Cir. 1987) 20 In re Sims v. Blot, 534 F.3d 117 (2d Cir. 2008) 14 In re Teligent, Inc., 640 F.3d 53 (2d Cir. 2011) 9 In re

4 (2019) of this litigation. Neither the truth onrerlying claims nor Dershowitz's denial thereo is fore the Court. Attorneys and Law Firms *566 Sigrid S. McCawley, Boies, Schiller & Flexner LLP, Fort Lauderdale, FL, Joshua Schiller, Boies Schiller Flexner LLP, New York, NY, for Plaintiff. Arthur Louis Aidala

t. 24, 2019). A few moments later, the Court again going to call ... I don't know if it's Ms. said to counsel fo [t]he defense says that they're McCawley or who, on the extortion issue," to which BSF confirmed, "Right, your Honor." (Tr. 66:12, Sept. 24, WESTLAW © 2020 Thomson Reuters. No claim to 2

s at publication, defined as the earliest date on which the work was placed on sale or became generally available to the public.' " Van Buskirk v. The New York Times Co. 325 F.3d 87, 89 (2d Cir. 2003) (Quoting Tomasino v. William Morrow & Co. 174 A.D.2d 734, 571 N.Y.S.2d 571, 572 (2d Dep't 1991)). Dershowitz invoke

Ip.com Cow. Judge/ Agency appealed tram: U.S. District Court for the Southern District of New York (Sweet J.) Plaintiff-Appellee OPPOSING ATTORNEY:Sigrid McCawley Please check appropriate boxes: I los movant notiftedr opposing counsel (mquied by Local Rub 27.1): ElYes jNo(explaii): OPPosbfi l's position o

J.) Plaintiff-Appellee OPPOSING ATTORNEY:Sigrid McCawley Please check appropriate boxes: I los movant no

Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 126 (2d Cir. 2006) (remanding to the district court for "specific, on-the-record findings"); In re New York Times Co., 828 F.2d 110, 116 (2d Cir. 1987) (observing that "[t]he job of protecting 4 EFTA00792269 Case 18-2868, Document 153-2, 03/19/2019, 2521600, Page

. 11 Before: 12 HON. LORETTA A. PRESKA, 13 District Judge 14 APPEARANCES 15 BOIES, SCHILLER & FLEXNER, LLP 16 Attorney for Plaintiff BY: SIGRID S. MCCAWLEY 17 HADDON, MORGAN, AND FOREMAN, P.C. 18 Attorney for Defendant BY: LAURA A. MENNINGER 19 20 21 22 23 24 25 SOUTHERN DISTRICT REPORTERS, P.

on to compel defendant to answer deposition questions. Unseal subject to the caveat which I won't keep saying. 144. Plaintiff's declaration of Ms. McCawley in support of the motion. Unseal. 144-1. Exhibit 1. Page 21 of Ms. Maxwell's April 22, 2016 deposition. Unseal. 144-2. Additional pages of Ms. Ma

st, 677 F.2d 230 (2d Cir. 1982) 25 v. Maxwell, 325 F. Supp. 3d 428 (S.D.N.Y. 2018) 6, 25, 40 In re Mazzeo, 167 F.3d 139 (2d Cir. 1999) 17 In re New York Times Co., 828 F.2d 110 (2d Cir. 1987) 37, 40 In re Teligent, Inc., 640 F.3d 53 (2d Cir. 2011) 1 Joy v. North, 692 F.2d 880 (2d Cir. 1982) 22 Louis Vuitt

016, I electronically served this Defendant's Response in Opposition to Motion to Exceed Presumptive Ten Deposition Limit via ECF on the following: Sigrid S. McCawley Meridith Schultz Boors, SCHILLER & FLEXNER, LLP Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FiSTOS & LEHRMAN, P.L. Paul G. Cassell 38

sition Limit via ECF on the following: Sigrid S. McCawley Meridith Schultz Boors, SCHILLER & FLEXNER, LLP

, and it is an absolute defense? Further, if Plaintiff cannot prove actual malice by Ms. Maxwell, her claim fails. See Contemporary Mission, Inc. v. New York Times Co., 842 F.2d 612, 621 (2d Cir. 1988) (limited purpose public figure must establish by clear and convincing evidence that the defendant published the a

ell's guilt. For example, Mr. Edwards opined that Ms. Maxwell was "a main facilitator" of Mr. Epstein's crimes who "started the whole thing." M Ms. McCawley praised the prosecutors: "[They] have done an incredible job and they're being very meticulous, they want to make sure that the Indictments stick. .

6-0022 FACSIMILE COVER SHEET TO: Laura Menninger, Esq. Haddon, Morgan and Foreman, P.C. Fax No. Telephone No. 303.832.2628 301831.7364 FROM: Sigrid S. McCawley, Esq. DATE: February 26, 2016 RE: v. Maxwell, Case no. 15-cv-07433-RWS Total Number of Pages: 26 (including this cover sheet) MESSAGE: Atta

was balanced against "the duty of the courts," id. at 602, including the duty to ensure fairness to the defendants, see id. at 602 n.14. In In re New York Times Co., 828 F.2d 110 (2d Cir. 1987), cited with approval in United States v. Longueuil, 567 Fed. App'x 13, 16 (2d Cir. 2014), Judge Weinstein denied the me

l's guilt. For example, Mr. Edwards opined that Ms. Maxwell was "a main facilitator" of Mr. Epstein's crimes who "started the whole thing." Id. Ms. McCawley praised the prosecutors: "[They] have done an incredible job and they're being very meticulous, they want to make sure that the Indictments stick. .

y was balanced against "the duty of the courts," id. at 602, including the duty to ensure fairness to the defendants, see W. at 602 n.14. In In re New York Times Co., 828 F.2d 110 (2d Cir. 1987), cited with approval in United States v. Longueuil, 567 Fed. App'x 13,16 (2d Cir. 2014), Judge Weinstein denied the med

2019 No Record Letter: 1476604-0 sent to Thomas McCawley of Boies, Schiller and Flexner LLP re•resentin•

: UP3 Letters: 14466832-0 sent to Mark Niquette of Bloomberg News on 09/18/2019 1445706-0 sent to Jake Morphonios on 08/30/2019 1445379-0 sent to The New York Times' Mike Baker on 08/29/2019 1445138-0 sent to ABC New's Halley Frequer on 08/23/2019 1443697-0 sent to Radical Media's Kevin Garnett on 08/06/2019 14