Epstein Secrets

, Ste. 2 Ft. Lauderdale, FL 33301 [email protected] J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 [email protected] Id Nicole Simmons Nicole Simmons 26 EFTA00605140

er, rescheduled the deposition of Mr. Rizzo in New York for a week after this Court had a hearing, rather than accommodating any attempt to have the New York deposition occur when all counsel were already present in NY. To the extent the Court wishes to consider the good faith efforts of defense counsel i

l A. Keough STEPTOE & JOHNSON, LLP 1114 Avenue of the Americas New York, NY 10036 [email protected] [email protected] [email protected] Is, Nicole Simmons Nicole Simmons EFTA00794012

ounsel again unilaterally served a deposition notice for October 25, 2018, in New York, knowing that counsel and Ms. Maxwell are not available for a New York deposition on that date. Given the thrice-served notices for Ms. Maxwell's depositions, each for dates and locations that either she or her counsel

F system which will send notification of such filing to the following: U.S. Attorney's Office, SDNY One Saint Andrew's Plaza New York NY 10007 s/ Nicole Simmons 46 EFTA00090772

defendant intended to engage in sexual 31 EFTA00090757 activity for which the defendant could be charged with specific New Jersey, Pennsylvania, New York, and Canadian criminal offenses" (emphasis added)). Accordingly, the Court should give the jury the defense's requested limiting instruction.' V. T

nninger in Support of Defendant’s Motion For Summary Judgment I, Laura A. Menninger, declare as follows: 1. Iam 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. Iam a member of the law firm Haddon, Morgan & For

ersity Street Salt Lake City, UT 84112 [email protected] J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 [email protected] /s/ Nicole Simmons Nicole Simmons HOUSE_OVERSIGHT_014658 --- PAGE BREAK --- Case 1:15-cv-07433-RWS Document 539-1 Filed 01/06/17 Page 1 of 9 EXHIBIT A HOUSE_OVERS