Epstein Secrets

: (212) 446-2300 Fax: (212) 446-2350 Email: [email protected] Email: [email protected] Email: [email protected] Email: [email protected] Sigrid McCawley (pro hac vice) Daniel Crispin (pro hac vice) Boies Schiller Flexner LLP 401 E. Las Olas Blvd. Suite 1200 Given Jane Doe 7's history of meritless

[email protected] Email: [email protected] Sigrid McCawley (pro hac vice) Daniel Crispin (pro hac vice) Bo

on—the method by which the Settlement Fund is distributed to the Class- "must be fair and adequate." Facebook, 343 F. Supp. 3d at 414 (quoting In re WorldCom, Inc. Sec. Litig., 388 F. Supp. 2d 319, 344 (S.D.N.Y. 2005)); see Fed. R. Civ. P. 23(e)(2). Where, as in this case, a Plan of Allocation is "formul

ertain to the Defendant refusing to answer questions during her deposition, directing to go ask the question of Epstein. See Mot. at 19-20 (citing McCawley Dec. at Exhibit 1, Epstein Depo. Tr. at 55:18-56:18 (in answer to question about massages, Defendant states: "I think you should ask that question

A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: Fax: Email: 21 /s/ Sigrid S. McCawley Sigrid S. McCawley EFTA00622198 United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine

Jenkens & Gilchrist, 362 F. Supp. 2d 407 (S.D.N.Y. 2004) 6 F.D.I.C. v. Fidelity & Deposit Co. of Maryland, 45 F.3d 969 (5th Cir. 1995) 6 In re WorldCom, Inc. Securities Litigation, 2005 WL 375315 (S.D.N.Y. Feb. 17, 2005) 17 LiButti v. United States, 107 F.3d 110 (2d Cir. 1997) passim Rules Fe

liability case. 4 MR. CASSELL: Right. So Epstein was the one who 5 provided the loan to get that -- 6 THE COURT: Says who? 7 MR. CASSELL: Ms. McCawley, who took Maxwell's 8 deposition, is advising me that during Maxwell's deposition, 9 she conceded that. 10 THE COURT: Well, all right. Okay. Bu

he kind of questions that have 16 been disapproved in the Second Circuit. And that's Brink's 17 Inc. v. City of New York, which is in the papers; WorldCom 18 Security Litigation, also in the papers; and LiButti itself. 19 These are not technical objections. It serves no legitimate 20 evidentiary p

ts into the liability case. MR. CASSELL: Right. So Epstein was the one who provided the loan to get that -- THE COURT: Says who? MR. CASSELL: Ms. McCawley, who took Maxwell's deposition, is advising me that during Maxwell's deposition, she conceded that. THE COURT: Well, all right. Okay. But that isn

he kind of questions that have 16 been disapproved in the Second Circuit. And that's Brink's 17 Inc. v. City of New York, which is in the papers; WorldCom 18 Security Litigation, also in the papers; and LiButti itself. 19 These are not technical objections. It serves no legitimate 20 evidentiary p