Epstein Secrets

Third Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: 303-831-7364 Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone

onjorno, 494 U.S. 827 (1990) 6 Kawashima v. Holder, 565 U.S. 478 (2012) 13 Landgraf v. USI Film Prod., 511 U.S. 244 (1994) passim Lattab v. Ashcroft, 384 F.3d 8 (1st Cir. 2004) 7 Leocal v. Ashcroft, 543 U.S. 1 (2004) 13 Martin v. Hadix, 527 U.S. 343 (1999) 7 Shular v. United States, 140

s are also open in New York City, Greenville, S.C., and Alpine, Utah, the state's largest district. Returns are planned in Charlotte, Baltimore and Denver." The Wall Street Journal <https://www.wsj.corn/articles/more-schools-are-reopening-as-covid-19-cases-rise- nationwide-11603114570> (10/19, Subscrip

State Jay Ashcroft is working with national, state and local leaders to bolster the state's defenses in the lead up to the Nov. 3 general election." Ashcroft said, "Our office is working hand-in-hand with federal, state and local officials to safeguard the integrity of Missouri's elections." His office "

s are also open in New York City, Greenville, S.C., and Alpine, Utah, the state's largest district. Returns are planned in Charlotte, Baltimore and Denver." The Wall Street Journal (10/19, Subscription Publication, 7.57M) reports that determining how and when to bring students back into classrooms has

tate Jay Ashcroft is working with national, state and local leaders to bolster the state's defenses in the lead up to the Nov. 3 general election." Ashcroft said, "Our office is working hand-in-hand with federal, state and local officials to safeguard the integrity of Missouri's elections." His office "w

PLY MEMORANDUM OF LAW IN SUPPORT OF DEFENDANT'S MOTION TO DISMISS COMPLAINT Laura A. Menninger HADDON, MORGAN AND FOREMAN, P.C. East 10th Avenue Denver, CO 80203 EFTA00591577 Case 1:15-cv-07433-RWS Document 25 Filed 12/28/15 Page 2 of 13 TABLE OF CONTENTS INTRODUCTION ARGUMENT I. PLAINTIFF FA

of defendant's letter was irrelevant. Instead, the letter was privileged because it amounted 5 Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007); Ashcroft v. lqbal, 556 U.S. 662 (2009). 6 Not surprisingly, Plaintiff does not cite to a single federal authority post Twombly and !ghat in support of her a

November 30, 2015. Respectfully submitted, s/ Laura A. Menninger Laura A. Menninger, Esq. HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 Phone: Fax: Attorney for Ghislaine Maxwell CERTIFICATE OF SERVICE I certify that on November 30, 2015, I electronically filed this Ghi

616, 630 (1919) 17 Adelson v. Harris, 973 F. Supp.2d 467, 477 (S.D.N.Y. 2013) 7 Armstrong v. Simon & Schuster, Inc., 625 N.Y.S.2d 477 (1995) 7 Ashcroft v. lqbal, 129 S. Ct. 1937, 1949 (2009) 6 Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007) 7 Biro v. Conde Nast, 883 F.Supp.2d 441, 457 (S

s are also open in New York City, Greenville, S.C., and Alpine, Utah, the state's largest district. Returns are planned in Charlotte, Baltimore and Denver." The Wall Street Journal (10/19, Subscription Publication, 7.57M) reports that determining how and when to bring students back into classrooms has

tate Jay Ashcroft is working with national, state and local leaders to bolster the state's defenses in the lead up to the Nov. 3 general election." Ashcroft said, "Our office is working hand-in-hand with federal, state and local officials to safeguard the integrity of Missouri's elections." His office "w