he claims also that she was directed by my client and the Epstein defendants to have sex with third parties, including Alan Dershowitz, for example,” Menninger said. “And so to the extent my client or Mr. Dershowitz or anyone else is going to be asked about their private sexual activity, I believe that would

ands of dollars from British tabloids with a motive for selling papers and advertisements and without regard for truth, veracity or substantiation,” Menninger noted in a 2016 response filed in the case. In February, the Miami Herald filed a federal court motion in the Southern District of New York, seeking

t: Re: [EXTERNAL] RE: questionnaires eff Pagliuca Thanks very much, sounds good, just let us know when you're ready. On Nov 7, 2021, at 12:11 PM, Menninger Thanks= We are finalizing ours as well and should be done shortly. From: Sent: Sunday, November 7, 2021 10:08 AM To: Subject: RE: questionnaires

ithdrawn our objection and joined your position that those jurors should proceed to voir dire. Those juror numbers are: 127, 151, and 458. Thanks, Menninger November 7 2021 3:03 PM Ann Lundberg Subject: RE: [EXTERNAL] RE: questionnaires Sorry Mut we did not use Excel to prepare our list, so I don't k

ands of dollars from British tabloids with a motive for selling papers and advertisements and without regard for truth, veracity or substantiation,” Menninger noted in a 2016 response filed in the case. In February, the Miami Herald filed a federal court motion in the Southern District of New York, seeking

he claims also that she was directed by my client and the Epstein defendants to have sex with third parties, including Alan Dershowitz, for example,” Menninger said. “And so to the extent my client or Mr. Dershowitz or anyone else is going to be asked about their private sexual activity, I believe that would

From: To: Nathan NYSD Chambers Cc: Menninger" Subject: US v. Maxwell, 20 Cr. 330 (AJN) - Def. Expert Notice Date: Mon, 08 Nov 2021 15:12:48 +0000 Attachments: Def_Expert_Noticelproposed_redac

ighly confidential materials, scenes Yes, that works for us, thank you very much. We can use the below dial-in: Dial-in: Code: Best, From: Laura Menninger <Imenninger@hmflawcom> Sent: Tuesday, March 9, 2021 11:19 AM To: ) (USANYS) Cc: Jeff Pagliuca <jpagliucaahmflaw.com>; Christian R Everdell - Cohen

y represents GHISLAINE MAXWELL in civil litigation (the "Laura Menninger Phone"). The most recent contact between Target Cellphone-I and the Laura Menninger Phone occurred in or about August 2019. f. Target Cellphone-1 has also been in contact with a phone subscribed to in the name of "Scott Borgerson,"

sents GHISLAINE MAXWELL in civil litigation (the "Laura Menninger Phone"). The most recent contact between The Target Cellular Device and the Laura Menninger Phone occurred within the last 30 days. 4 EFTA00018667 --- PAGE BREAK --- b. The Target Cellular Device has also been in contact with a phone su

, From: Christian Everdell < Sent: Monday, March 29, 2021 2:40 PM To: (USANYS) ‹ > Cc: 'Jeff Paghuca' Subject: Discovery Issues -)< >; Laura Menninger >; Bobbi Sternheim and a — We write to raise a few issues concerning the discovery. Below is the list of items. Please let me know if you are fre

: 2020-08-10 J01100-00OLLETTEtaddressettojudge_Loretta_A.freskafrom_....pdf; 2020-08-10 J01100-001LExhibit_A.PDF Are you able to shed light on what Menninger is trying to intimate in this first paragraph? I just want to prepare if there is something I need to know about. This letter comes as part of the u

From: " To: ' C (USANYS)" cz IMIE> a =nr Menninger , Jeff Pa8„ uca Laura (USANYS) [Contractor Subject: US v. Maxwell, 20 Cr. 330 (MN) Date: Sat, 20 Nov 2021 19:53:28 +0000 Attachments: 2021.11.20

rst group filed and then send you the next batch. From: Christian Everdell <[email protected]> Sent: Friday, October 29, 2021 5:42 PM To: Menninger <Imenninger hmflaw.com>; Jeff Pagliuca <jpagliucaP hmflaw.com> ; BOBBI C STERNHEIM <[email protected]>; Laura Cc: EFTA00023464 --- PAGE BREAK

our letter. Thanks very much, and hope everyone has a nice weekend-- From: BOBBI C STERNHEIM Sent: Friday, May 7, 2021 5:26 PM Christian Everdell Menninger Jeff Pagliuca Subject: Re: United States v. Ghislaine Maxwell, 20 Cr. : Laura We are available to begin November 8th and to conclude by the end o

[email protected]> Sent: Sunday, October 18, 2020 10:47 PM To: )'< > Cc: I *c >; (USANYS) < ; Mark S. Cohen <[email protected]>; Laura Menninger <Imenning @hmflaw.com>• Jeff Pagliuca <[email protected]>• Bobbi Sternheim ([email protected]) <[email protected]> Subject: Re: US v. Maxwell

l to discuss? Thanks, From: Christian Everdell ‹ > Sent: Monday, March 29, 2021 2:40 PM To: ) c >; >"; (USANYS) Cc: 'Jeff Pagliuca' < >; Laura Menninger Bobbi Sternheim ) Subject: Discovery Issues and M — We write to raise a few issues concerning the discovery. Below is the list of items. Please l

was sure. 17 MS. McCAWLEY: Dr. Olsen has been noticed for 18 deposition in Colorado already. In my view, we have disclosed 19 the doctors. Ms. Menninger says that there is other doctors 20 that have been disclosed in documents that we have not yet 21 listed to her. I think in discovery we are find

From: Christian Everdell <CEverdell@CohenGressencom> Sent: Thursday, October 1, 2020 3:28 PM To: Cc: Mark S. Cohen <mcohen@CohenGressencom>. Laura Menninger <[email protected]>• Jeff Pagliuca <jpagliticaPhmflaw.com>; Subject: RE: US v. Maxwell - discovery production Tom Powers from our office will b

t my client. THE COURT: And that's it. MS. McCAWLEY: Yes, your Honor. THE COURT: Let me ask the defense. Does that clarify anything for you? MS. MENNINGER: Could I have one second, your Honor? THI 1a COURT Sure. Of course. MS. MENNINGER: Your Honor, I think it's slightly more nuanced. Plaintiff has

From: ' y 1 I 1 < To: Christian Everdell <CEverdell CohenGresser.com>, 'Laura Menninger' <Imennin er hmflaw.com>, ' (USANYS)" Cc: Jeff Paglitica <jpagliucaghmflaw.com>, 'BOBS! C STERNHEIM' <bcstemheimgmac.com> Subject: RE: US v. Max

WS VIRGINIA GIUFFRE, Plaintiff, ve GHISLAINE MAXWELL, Defendant. 1 (Pages 1 to 4) VOLUME 1 (pages 1 - 157) TONY FIGUEROA Direct Examination by Ms. Menninger 5 OATH OF REPORTER 156 CERTIFICATE OF REPORTER 157 9 i VOLUME 2 (Pages 158 - 258) | VIDEOTAPED DEPOSITION OF TONY FIGUEROA 10 ; lime TFS TONY FIGU