3
Shared Docs
3
Same-Page
3 / 3
Mentions
ee also LeBlanc v. Cleveland, 248 F.3d 95, 100 (2d Cir. 2001). The complaint was filed on September 21, 2015 at which time Plaintiff was living in Colorado and Defendant Ghislaine Maxwell was living in New York. Plaintiff is a United States Citizen. Plaintiff is seeking damages in excess of $75,000.00
expected and intended, the media obtained copies of the motion. At issue is a January 2, 2015, statement prepared by Ms. Maxwell's British solicitor Philip Barden. Mr. Barden sent the statement to Ms. Maxwell for approval and, following approval, caused Mr. Gow to send (via email) the statement to six to thir
ee also LeBlanc v. Cleveland, 248 F.3d 95, 100 (2d Cir. 2001). The complaint was filed on September 21, 2015 at which time Plaintiff was living in Colorado and Defendant Ghislaine Maxwell was living in New York. Plaintiff is a United States Citizen. Plaintiff is seeking damages in excess of $75,000.00
expected and intended, the media obtained copies of the motion. At issue is a January 2, 2015, statement prepared by Ms. Maxwell's British solicitor Philip Barden. Mr. Barden sent the statement to Ms. Maxwell for approval and, following approval, caused Mr. Gow to send (via email) the statement to six to thir
ttorney-client privilege" with respect to the Barden communications and broadly asserts that all privileges asserted are "pursuant to British law, Colorado law and NY law." Privilege Log at 1. Defendant argues "Ms. Maxwell's communications with Mr. Barden should be construed pursuant to British law." D
dant has withheld 99 pages of emails with communications involving various combinations of Brett Jaffe, Esq. ("Jaffe"), Mark Cohen, Esq. ("Cohen"), Philip Barden ("Barden"), Ross Gow ("Gown), Brian Basham ("Basham"), and The facts that follow summarize Defendant's assertions regarding her relationship to e
Entities connected to both Colorado and Philip Barden

Jeffrey Epstein
PERSON
Denver
LOCATION
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
United States
LOCATION
Virginia Giuffre
PERSONMartin Weinberg
PERSONJeffrey Pagliuca
PERSON
Bill Clinton
PERSON
Wilbur Ross
PERSONEmmy Taylor
PERSON
Bradley Edwards
PERSON
Cleveland
LOCATIONMaria Farmer
PERSON
Tony Blair
PERSONSouthern District
LOCATIONLaura Menninger
PERSON
Alan Dershowitz
PERSON
Alfredo Rodriguez
PERSON