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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
n's Fund Am. Life Ins. Co., 819 F.2d 1471 (8th Cir. 1987) 7, 8 Denney v. 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. U
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
, oh, it's never been applied in a case like this. I would just direct your attention, as I did during the Epstein argument, to the case of FDIC v. Fidelity & Deposit Co. of Maryland. That's a Fifth Circuit case from 1995, in which a bank officer was accused of dishonest and fraudulent acts and kind of bogus loans,
, I don't see how that gets 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'
s, oh, it's never been applied in a case like this. I would just direct your attention, as I did during the Epstein argument, to the case of FDIC v. Fidelity & Deposit Co. of Maryland. That's a Fifth Circuit case from 1995, in which a bank officer was accused of dishonest and fraudulent acts and kind of bogus loans, and
Entities connected to both Sigrid McCawley and Fidelity & Deposit Co.

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSON
Alan Dershowitz
PERSONLaura Menninger
PERSONJeffrey Pagliuca
PERSONthe Southern District
LOCATION
Colorado
LOCATION
Lesley Groff
PERSON
Sergey Brin
PERSON
Juan Alessi
PERSONScott Rothstein
PERSON
South Florida
LOCATION
Barden
PERSONLiButti
PERSON
Diane Flores
PERSONWorldCom
ORGANIZATIONCrescenz v. Penguin Group
ORGANIZATIONPagan
PERSON