Epstein Secrets

Response in Opposition to Extending Deadline to Complete Depositions and Motion for Sanctions for Violations of Rule 45 via ECF on the following: Sigrid S. McCawley Meridith Schultz BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 [email protected] mschultz@b

ena for and a letter of production from Sigrid McCawley of June 17, 2016, designated as Confidential by P

ibit J (filed under seal) 12. Attached as Exhibit K (filed under seal) are Notices of Deposition and Subpoena for and a letter of production from Sigrid McCawley of June 17, 2016, designated as Confidential by Plaintiff under the Protective Order. 2 EFTA00605142 Case 1:15-cv-07433-RWS Document 229 Filed 06

State of New York and admitted to practice in the United States District Court for the Southern District of New York. I am a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell ("Maxwell") in this action. I respectfully submit this declaration in support of Defendant

ue to pursue Maxwell to try to get service on her in the action, will your firm agree to accept service on her behalf of that complaint? Thanks, Sigrid Sigrid McCawley Partner ROTES SCHILLER FLEXNER LLP 401 E. Las Olas Blvd. Suite 1200 Fort Lauderdale, FL, 33301 This email chain and with relate

efforts continued — unsuccessfully — to arrange service through the Haddon Morgan firm. For example, on May 9, 2017, co-counsel for Jane Doe 43 (Ms. Sigrid McCawley at Boies Schiller) sent an email to Mr. Pagliuca as follows (id. at 3-4): From: Sigrid McCawley Sent: Tuesday, May 09, 017 4:33 PM To: Jeff Pagli

y 9, 2017, co-counsel for Jane Doe 43 (Ms. Sigrid McCawley at Boies Schiller) sent an email to Mr. Pagliuca

f Notices of Electronic Filing generated by CM/ECF. Kimo S. Peluso Sher Tremonte, LLP 90 Broad Street, 23nd Floor New York, NY 10004 Counsel for Haddon, Morgan & Foreman, P.C. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Michael C. Mil

liuca In Support Of Defendant's Motion In Limine to Exclude Expert Testimony and Opinion of Professor Terry Coonan, J.D. via ECF on the following: Sigrid S. McCawley Meredith Schultz BOLES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale. FL 33301 Bradley J. Edwards FARMER, JAFF

Coonan, J.D. via ECF on the following: Sigrid S. McCawley Meredith Schultz BOLES, SCHILLER & FLEXNER, LLP

rado and admitted to practice in the United States District Court for the Southern District of New York pro hac vice. I am a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell ("Maxwell") in this action. I respectfully submit this declaration in support of the Motio

igned counsel, and serves this revised disclosure pursuant to Fed. R. Civ. P. 26 and states as follows: A. Witnesses: I. Virginia L. Giuffre c/o Sigrid S. McCawley, Esq. Boles, Schiller & Flexner LLP 401 East Las Olas Boulevard, Suite 1200 Miami, Florida 33301 Tel: (954) 356-0011 Email: [email protected]

O PLAINTIFF via ECF on the following: Sigrid S. McCawley BOLES, SCHILLER & FLEXNER, LLP 401 East Las Ola

State of New York and admitted to practice in the United States District Court for the Southern District of New York. I am a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell ("Maxwell") in this action. I respectfully submit this declaration in support of Defendant

t's Reply In Support Of Motion In Limine To Exclude In Toto Certain Depositions Designated By Plaintiff For Use At Trial via ECF on the following: Sigrid S. McCawley Paul G. Cassell Meredith Schultz 383 S. University Street BOLES, SCHILLER & FLEXNER, LLP Salt Lake it UT 4112 401 East Las Olas Boulevard, Ste.

Use At Trial via ECF on the following: Sigrid S. McCawley Paul G. Cassell Meredith Schultz 383 S. Univer

State of New York and admitted to practice in the United States District Court for the Southern District of New York. I am a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit this Declaration in support of Ms. Maxwell's Reply t

fessional relationships as well as matters concerning her private affairs." • March 17, 2016 (DE 66 at 9): At hearing on the Protective Order, Ms. McCawley stated "I can have the deposition of the defendant in this case and move this case forward. I will agree to their protective order. I just want tha

aration of Laura A. Menninger in Support of Ms. Maxwell's Reply In Support of Her Objection to Unsealing Sealed Material via ECF on the following: Sigrid S. McCawley Meredith Schultz Bows, $CHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale. FL 33301 Bradley J. Edwards Stan J. Potti

State of New York and admitted to practice in the United States District Court for the Southern District of New York. I am a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell ("Maxwell") in this action. I respectfully submit this declaration in support of Ms. Maxwe