ached by Ghislaine Maxwell," and continuing that "Maxwell persuaded Jane Doe 143 (who was only fifteen years old) to come to Epstein's mansion ..." Menninger Decl., N. A at 26-29. No amount of "circumstantial evidence" can overcome the fact that Ms. Maxwell's statement was correct and that statements in the Jo

Court," as referenced in Motion for Paul Cassell to Appear (Doc. #112), because defense counsel had not received any such supplemental materials. [Menninger Decl. Ex. A]. Ms. McCawley responded that her "staff is scanning them to you now. You should have them shortly." Id. At 5:49 p.m., Plaintiff's counsel se

concerning "numerous American politicians, powerful business executives, foreign presidents, a well-known Prime Minister, and other world leaders." Menninger Decl., Ex. C at 5. Plaintiff's story is palpably incredible, as even Judge Marra suggested in his Order. In any event, New York courts uniformly agree g

threats to people on the telephone? MR. PAGLIUCA: Object to form and foundation. 3 EFTA00595615 THE WITNESS: Yes. He wasn't always friendly See Menninger Decl., Ex. F, 10:6-14; 43:15-44:4 As explained in in Wright & Miller, Federal Practice and Procedures, the use of a document during testimony to refresh

ty participated in this email 19 EFTA R1 00011995 EFTA01734205 Case 1:15-cv-07433-RWS Document 125 Mled O5/02i16 Page 20 of 31 correspondence." Menninger Decl. 1 117 Supp. Reply at 5 n.2, Documents .11045-46 contain communications between Defendant and Barden; however, documents 81047-51 -include Gow (and