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al in full. 211. That's the reply to the motion. The portions mentioning Does 1 and 2 which appear at pages 2, 5, and 6 may be unsealed. 212. Ms. Schultz's declaration in support of the motion. The portions mentioning John Does 1 and 2 which appear at page 2 may be unsealed. 212-1. Doe no. 162's dep
20, denying Ms. Maxwell's motion to reconsider. Dated: July 29, 2020. Respectfully submitted, s/ Laura A. Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) Ty Gee (pro hac vice) HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Ghislaine Maxwell 1 EFTA00076389 CasastrabiAZI71432)IaAini
Sorry. No. 6 Thanks very much. 7 MR. CASSELL: Thank you, your Honor. 8 THE COURT: Anything from the defense. 9 MR. PAGLIUCA: Yes, your Honor. Jeff Pagliuca on 10 behalf of Ms. Maxwell. 11 Your Honor, I have never opposed a pro hac motion in 12 my 34 years of practice, so this is a first for me. But
23 24 25 Case 20-2413, Document 44, 08/20/2020, 2913556, Page67 of 78 K7N9GIUD App.-0841 150. Declaration of Mister how does he say it, Mr. Pagliuca? Say it again. MS. MENNINGER: Pagliuca. THE COURT: Mr. Pagliuca in opposition to the motion to compel. Unseal. 150-1. Additional pages from Ms. M
al in full. 211. That's the reply to the motion. The portions mentioning Does 1 and 2 which appear at pages 2, 5, and 6 may be unsealed. 212. Ms. Schultz's declaration in support of the motion. The portions mentioning John Does 1 and 2 which appear at page 2 may be unsealed. 212-1. Doe no. 162's dep
7 K7N9GIUD 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 150. Declaration of Mister -- how does he say it, Mr. Pagliuca? Say it again. MS. MENNINGER: Pagliuca. THE COURT: Mr. Pagliuca in opposition to the motion to compel. Unseal. 150-1. Additional pages from Ms. M
al in full. 211. That's the reply to the motion. The portions mentioning Does 1 and 2 which appear at pages 2, 5, and 6 may be unsealed. 212. Ms. Schultz's declaration in support of the motion. The portions mentioning John Does 1 and 2 which appear at page 2 may be unsealed. 212-1. Doe no. 162's dep
4 K7N9GIUD 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 150. Declaration of Mister -- how does he say it, Mr. Pagliuca? Say it again. MS. MENNINGER: Pagliuca. THE COURT: Mr. Pagliuca in opposition to the motion to compel. Unseal. 150-1. Additional pages from Ms. M
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 304-3. Same. Keep sealed. Medical records. 304-4. Letter from Ms. Menninger to Ms. Schultz. Unsealed but redact the medical information. 313. Supplemental authority. That has already been publicly filed. 313-1. Plaintiff's supplemental
ame reason. Pages 20 to 23. Testimony from or about the Does. The shaded material shall remain sealed except for Detective 340. Declaration of Mr. Pagliuca. Unseal and redact only the names and identifying information of the nonparties. I will note Detective is in there and Ms. Maxwell's depositions
Entities connected to both Schultz and Jeffrey Pagliuca

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSON
Michael Cohen
PERSON
Denver
LOCATION
Prince Andrew
PERSONSouthern District
LOCATION
Colorado
LOCATION
Foreman
PERSON
Department of Justice
ORGANIZATION
David Boies
PERSONSigrid McCawley
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Julie K. Brown
PERSONthe Southern District
LOCATION
Stephen Hawking
PERSON
Paul Cassell
PERSON
Nicole Simmons
PERSON
Audrey Strauss
PERSONLeon Black
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