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navailable Deposition of Alfredo Statements regarding Alfredo Rodriguez is See Motion to Exclude Depositions In Toto and Motion in Limine re: Diane Flores 4 EFTA00617182 Rodriguez and handwriting on exhibits. Ms. Maxwell's involvement in massages given to girls and young adults, as partic
X 15-cv-07433-RWS RESPONSE TO PLAINTIFF'S NOTICE OF INTENT TO OFFER STATEMENTS UNDER, IF NECESSARY, THE RESIDUAL HEARSAY RULE Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 EFTA00617178 Defendant Ghislaine Maxwell ("Ms. Maxwell") hereby
DUAL HEARSAY RULE Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 Ea
we argued it a couple weeks ago in the 16 context of another motion -- oh, I'm sorry, because, your 17 Honor, you requested that with respect to Diane Flores. So we 18 didn't reargue it today, it is fully briefed for you. 19 THE COURT: Okay. In other words, I've got everything 20 on that. 21 MS. Mc
ly, your Honor, I think you can 10 just see from the upset there what's going to be happening at 11 this trial. This is the direct quote from Mr. Pagliuca. 12 "Fantastical conspiracy". That's going to be the argument from 13 the other side. They're obviously entitled to advance that 14 argument. B
forget, we argued it a couple weeks ago in the context of another motion -- oh, I'm sorry, because, your Honor, you requested that with respect to Diane Flores. So we didn't reargue it today, it is fully briefed for you. THE COURT: Okay. In other words, I've got everything on that. MS. McCAWLEY: You do,
ly, your Honor, I think you can 10 just see from the upset there what's going to be happening at 11 this trial. This is the direct quote from Mr. Pagliuca. 12 "Fantastical conspiracy". That's going to be the argument from 13 the other side. They're obviously entitled to advance that 14 argument. B
I forget, we argued it a couple weeks ago in the context of another motion -- oh, I'm sorry, because, your Honor, you requested that with respect to Diane Flores. So we didn't reargue it today, it is fully briefed for you. THE COURT: Okay. In other words, I've got everything on that. MS. McCAWLEY: You do, yo
: In reply, your Honor, I think you can just see from the upset there what's going to be happening at this trial. This is the direct quote from Mr. Pagliuca. "Fantastical conspiracy". That's going to be the argument from the other side. They're obviously entitled to advance that argument. But that's wh
Entities connected to both Diane Flores and Jeffrey Pagliuca

Ghislaine Maxwell
PERSONLaura Menninger
PERSON
Jeffrey Epstein
PERSON
Colorado
LOCATIONSigrid McCawley
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Paul Cassell
PERSONSecond Circuit
ORGANIZATION
Virginia Giuffre
PERSON
Alan Dershowitz
PERSON
Lesley Groff
PERSONJack Goldberger
PERSON
Juan Alessi
PERSONJoe Recarey
PERSONScott Rothstein
PERSON
Barden
PERSON
Sergey Brin
PERSONLiButti
PERSON
Gotti
PERSON