Epstein Secrets

ow. I will try to get back to you on Monday or Tuesday with an answer. Jeffrey S. Pagliuca Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 Main 7 EFTA00792803 In follow up conversations, Mr. Pagliuca indicated that he was unable to provide the information that Mr. E

unsuccessfully — to arrange service through the Haddon Morgan firm. For example, on May 9, 2017, co-counsel for Jane Doe 43 (Ms. Sigrid McCawley at Boies Schiller) sent an email to Mr. Pagliuca as follows (id. at 3-4): From: Sigrid McCawley Sent: Tuesday, May 09, 017 4:33 PM To: Jeff Pagliuca Subject: Servi

uth Salem, New York 10590 18 BY: STAN POTTINGER, ESQUIRE 19 On Behalf of Defendant: 20 HADDON MORGAN FOREMAN 21 Attorneys for Defendant 22 Denver, Colorado 80203 BY: JEFFREY S. PAGLIUCA, ESQUIRE 23 LAURA A. MENNIGER, ESQUIRE 24 Also Present: 25 MAGNAO LEGAL SERVICES EFTA00083934 Con

uca and 11 Laura Menninger, on behalf of Ms. 12 Maxwell. 13 And Ms. McCawley has also entered 14 the room, and we have an assistant from 15 Boies Schiller from the Fort Lauderdale 16 office here today as well today. 17 THE VIDEOGRAPHER: Will the court 18 reporter please swear in the witness. 19

s District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, r.0 Ty Gee 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 HI 303.832.2628 www.hmtlaw.com [email protected] Re: Reconsideration of the Court's July 23 Ruling Giuffie v. Ghis

tion that it properly was a recipient of the material: [W]hatever Cooper & Kirk's intentions in requesting and obtaining the Maxwell materials from Boies Schiller, the Maxwell Protective Order explicitly provides that (1) discovery materials designated CONFIDENTIAL cannot be EFTA00094806 Case 1:15-cv-07433-

s District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, P C Ty Gee 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 HI 303.832.2628 www.hmllaw.com [email protected] Re: Reconsideration of the Court's July 23 Ruling Giuffie v. Ghis

tion that it properly was a recipient of the material: [W]hatever Cooper & Kirk's intentions in requesting and obtaining the Maxwell materials from Boies Schiller, the Maxwell Protective Order explicitly provides that (1) discovery materials designated CONFIDENTIAL cannot be EFTA00075057 Caest 131-63.403481

TO BOIES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303-831-7364 Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600

o prosecutors for the purpose of fomenting an investigation. But I am not faced with that situation. Nothing in this record suggests to me that or Boies Schiller had anything to do with the Government's decision to convene a grand jury to look into the matters that were the subject of the Action. On the con

TO BOLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303-831-7364 Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Bobbi C. Stern

) the government acted in good faith; and (3) the government inevitably would have come to possess the 90,000-sum pages of material it obtained from Boies Schiller. The facts and law belie the government's claims. A. Maxwell has standing. The government's standing argument boils down to this: Maxwell cannot c

s District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, P.0 Ty Gee 150 East 10th Avenue Denver, Colorado 80203 ni 303.831.7364 rx 303.832.2628 www.hmtlaw.com tgeefghmflaw.com Re: Reconsideration of the Court's July 23 Ruling Giuffre v. Ghi

1, 2020, the Court said it was "troubled" to learn that plaintiff's successor counsel, Cooper & Kirk, had received from plaintiff's former counsel, Boies Schiller Flexner, various discovery materials that were subject to the Protective Order. Doc.1071 at 4. The Court rejected Cooper & Kirk's suggestion that i

udge Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, r c Laura A. Menninger ISO East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 EX 303.832.2628 www.hmflaw.com [email protected] Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Obj

rocedure are being released to the public under the= unsealing process, without objection from the government. The name of the subpoena recipient (Boies Schiller) and the names of Chief Judge McMahon and Magistrate Judge Netburn (who issued their rulings nearly two years ago) certainly cannot alone compromis