Epstein Secrets

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

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 each of th

on January 6, 2015, #1030-43. c. Jaffe on March 15, 2011, #1000-19.2 Gow on January 2, 2011, #1020-26. Gow and Basham on January 2, 2015, #1027- Barden #1059-83, Some emails were forwarded or carbon copied ("CC'd") later in the chain, leading to some overlap and duplication. Whether one party or

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

d, 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 thirty members of

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

d, 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 thirty members of

15 at 2:44:39 PM EDT To: Laura A. Menninger Haddon, Morgan and Foreman, P.C. > > EFTA_R1_02007654 EFTA02684894 150 East 10th Avenue Denver, Colorado 80203 Kathryn H. Ruemmler LATHAM & WATKINSLLP 555 Eleventh Street, NW Suite 1000 Washington, D.C. 20004-1304 This email may contain material th

From: G Maxwell Sent: Thursday, October 8, 2015 8:31 PM To: jeffrey E. Subject: Re: Attachments: image001jpg You mean laura menniger? Barden already called.. THE TERRAMAR PROJECT <http://theterramarproject.org/> From: J Jep Date: Thursday, October 8, 2015 at 13:31 PM To: GG Subject: F

DT To: «mailto:KATHYRUEMMLE </=pan> <=pan style="color:#1f497d">Laura A. Menninger Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 Main =03.831.7364 <tel FX 3 <tel <mailto www.hmflaw.com <http://www.hmflaw.com> Kathryn H. Ruemmler LATHAM & WATKINSLLP 555 Eleventh St

l Subject: Re: dont you have a new york laweyr , not laura On Thu, Oct 8, 2015 at 4:31 PM, G Maxwell a <mailtc wrote: You mean laura menniger? Barden already called.. THE TERRA=AR PROJECT <http://theterramarproject.org/> From: J Jep Date: Thursday, October 8, 2015 at =3:31 PM EFTA_R1_02009280

> 1 EFTA_R1_01602488 EFTA02484513 <=pan style="color:#1f497d">Laura A. Menninger Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 Main =03.831.7364 <-> FX <te > [email protected]= <mailto:Imenninger@hm=law.com> www.hmflaw.com <http://www.hmflaw.com> Kathryn H. Rue

M To: G Maxwell Subject: Re: dont you have a new york laweyr , not laura On Thu, Oct 8, 2=15 at 4:31 PM, G Maxwell < You mean laura menniger? Barden already called.. THE TERRA=AR PROJECT <http://theterramarproject.org/> From: J Jep Date: Thursday, October 8, 2015 at =3:31 PM To: GG Subject: F

Date: October 7 2015 at 2:44:39 PM EDT To: «mailt </=pan> <= an s le="color:#1f497d">Laura A. Menninger Haddon, Morgan and Foreman, P.C. Denver Colorado 80203 Main www.hmflaw.com <http://www.hmflaw.com> Kathryn H. Ruemmler LATHAM & WATKINSLLP Washington, D.C. 20004-1304 2 EFTA_R1_01603126 EFTA

G Maxwell Subject: Re: dont you have a new york laweyr , not laura On Thu, Oct 8, 2015 at 4:31 PM, G Maxwell a wrote: You mean laura menniger? Barden already called.. THE TERRA=AR PROJECT <http://theterramarproject.org/> From: J Jep Date: Thursday, October 8, 2015 at =3:31 PM EFTA_R1_01603125

sage: From: < > Date: October 2O1 at 2: : PM EDT To: < > Laura A. Menninger Haddon, Morgan and Foreman, P.C. 150 East loth Avenue Denver, Colorado 80203 Main FX EFTA00714354 Kathryn H. Ruemmler LATHAM a, WATKINSLLP 555 Eleventh Street, NW Suite 1000 Washington, D.C. 20004-1304 Direct D

714353 dont you have a new york laweyr , not laura On Thu, Oct 8, 2015 at 4:31 PM, G Maxwell <GMaxl(aellmax.com> wrote: You mean laura menniger? Barden already called.. THE TERRAMAR PROJECT From: J lep Date: Thursday, October 8, 2015 at 13:31 PM To: G G Subject: Fwd: 5ok retainer Forwarded m

. McCAWLEY: Okay. 21 THE COURT: Does that work for you all? 22 MR. PAGLIUCA: I can't do the 10th, your Honor, I'm in 23 a deposition all day in Colorado. I'm sorry. 24 THE COURT: How could you possibly take another case? 25 MR. PAGLIUCA: Well, believe me, I have a lot of SOUTHERN DISTRICT REPORTE

fered for the truth of 5 the matter asserted, we want to offer it to show Ms. Maxwell's 6 state of mind when she issued her statement through Mr. Barden 7 and Mr. Gow. So the huge problem with that, your Honor, which 8 we've already dealt with, is, Ms. Maxwell has no knowledge of 9 what's in the

he 10th. MS. McCAWLEY: Okay. THE COURT: Does that work for you all? MR. PAGLIUCA: I can't do the 10th, your Honor, I'm in a deposition all day in Colorado. I'm sorry. THE COURT: How could you possibly take another case? MR. PAGLIUCA: Well, believe me, I have a lot of SOUTHERN DISTRICT REPORTERS, P.C.

fered for the truth of 5 the matter asserted, we want to offer it to show Ms. Maxwell's 6 state of mind when she issued her statement through Mr. Barden 7 and Mr. Gow. So the huge problem with that, your Honor, which 8 we've already dealt with, is, Ms. Maxwell has no knowledge of 9 what's in the