Epstein Secrets

SUPPORT OF MOTION TO COMPEL NON-PRIVILEGED DOCUMENTS Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN. P.C. East 101h Avenue Denver. CO 80203 EFTA00618132 Case 1:15-cv-07433-RWS Document 191 Filed 06/06/16 Page 2 of 15 TABLE OF CONTENTS INTRODUCTION 1 I. Plaintiff Concedes

ege log on which the Motion is based at Menninger Decl. at Ex. A. 6 One does wonder why a New York licensed attorney who claims to be practicing in the State of New York at an address within the Southern District would need to move for Pro Hac Vice admission in the jurisdiction he allegedly practices if he truly doe

conduct that is the subject of this action 2. Ghislaine Maxwell do Laura A. Menninger, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East le Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Email: Imenningerehmflaw.com Defendant in this action. EFTA_R1_00011974 EFTA01734184 Case 1:15-cv-07433-RW

to Defendant's First Set of Discovery Requests to Plaintiff 1, Laura A. Menninger, declare as follows: 1. I am an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. I am a member of the law firm Haddon, Morgan &

NS DESIGNATED BY PLAINTIFF FOR USE AT TRIAL Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 EFTA00595612 Defendant Ghislaine Maxwell ("Ms. Maxwell") files her Reply in Support of the Motion in Limine to Exclude In Toto certain

Certain Depositions Designated By Plaintiff For Use At Trial I, Laura A. Menninger, declare as follows: 1. I am an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. I am a member of the law firm Haddon, Morgan &

ger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) Ty Gee (pro hac vice) Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver. CO 80203 Phone: Fax: Attorneys for Ghislaine Maxwell 21 EFTA00074984 Ca a:Mag0743tikIcAlPneDbt0rfiefiFO7203(11O3913/%1382eartafr 01246f 22 C

ly In Support of Her Objection to Unsealing Sealed Materials I, Laura A. Menninger, declare as follows: 1. I am an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. I am a member of the law firm Haddon, Morgan &

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the constitution, by-laws, customs and interpretations of the marketplace where executed and govemed by and construed in accordance with the laws of the State of New York and all applicable federal laws and regulations. Further information with respect to commissions and other charges related to the execution of trans