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From:' "G To:' " Subject: FW: Maxwell Date: Mon, 15 Jul 2019 19:46:42 +0000 Importance: Normal Inline-Images: image004.jpg; image001.jpg Is this call at 4 happening, or have we heard from her new counsel? From: Jeff Pagliuca Sent: Tuesday, July 9, 2019 6:56 PM To: Cc: Nicole Simmons Subject: RE: Maxwell Hello, I expect you all have been busy in the last few days. When we spoke yesterday I understood that you would be sending a form proffer letter for my review. I would like to discuss the document with my client as soon as possible to keep the process moving. When you get a chance please send the draft and I will hopefully be in a position to discuss a potential proffer mating during our next call which I think is scheduled for 7-11 at 4pm my time. Best Regards, Jeff Jeffrey S. Pagliuca Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 www.hmflaw.com CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previou
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From:' "G To:' " Subject: FW: Maxwell Date: Mon, 15 Jul 2019 19:46:42 +0000 Importance: Normal Inline-Images: image004.jpg; image001.jpg Is this call at 4 happening, or have we heard from her new counsel? From: Jeff Pagliuca Sent: Tuesday, July 9, 2019 6:56 PM To: Cc: Nicole Simmons Subject: RE: Maxwell Hello, I expect you all have been busy in the last few days. When we spoke yesterday I understood that you would be sending a form proffer letter for my review. I would like to discuss the document with my client as soon as possible to keep the process moving. When you get a chance please send the draft and I will hopefully be in a position to discuss a potential proffer mating during our next call which I think is scheduled for 7-11 at 4pm my time. Best Regards, Jeff Jeffrey S. Pagliuca Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 www.hmflaw.com CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previou
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Ca_4ate.24h24/43134.01FrietibtOrtlefifitin0a0le28013,8111$2eafiabef146f 22
Ca_4ate.24h24/43134.01FrietibtOrtlefifitin0a0le28013,8111$2eafiabef146f 22 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Reply In Support Of Iler Objections to tnsealinu Sealed Materials Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue EFTA00074964 Ca_QatIgt24743tictoWneDbtOrfiefiVIMOXIle?BOWERKVaffizte12401 22 Introduction This Court asked the parties to brief three issues: "(a) the weight of presumption of public access that should be afforded to an item, (b) the identification and weight of any countervailing interests supporting continued sealing/redaction of the item, and (c) whether the countervailing interests rebut the presumption of public access to the item." DE 1044 at 1. Plaintiff and the Miami Herald's responses improperly afford the highest level of presumption to discovery dispute documents, deny that any co
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Cagean.g0c44/ 71SEAFierbd664164i igl5V2PilaW6M/Joagria44 1?)f 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Objections to Unsealing Docket Entries 143. 173. and 199 and to Unsealing Docket Entries 164 and 230 at This Time. Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 EFTA00075004 CageaUlg0caAIDer0dthhilfii igl5V2Pil&iA6/2bagctacir4 2%f 3 Defendant Ghislaine Maxwell, through her counsel and pursuant to this Court's Order and Protocol for Unsealing Decided Motions, DE 1044, as clarified by DE 1053, objects to the unsealing of the Sealed Items contained in: • DE 143 (and related DEs 142, 144, 144-1, 149, 150, 150-1, 151, 152, 153, and 153- 1); • DE 172 (and related DEs 171, 173, 173-1, 189, 190, 190-1, 202, 203, 204-1, 211, 212, 212-1, and 224) and; • DE 199 (and related DEs 200, 200-1, 228,2 29,
Maxwell Disputes
Case 18-2868, Document 284, 08/09/2019, 2628244, Page1 of 38 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------X Plaintiff, v. GHISLAINE MAXWELL, Defendant. -------------------------------------------------- ............................................. VIRGINIA L. GIUFFRE, 15-cv-07433-RWS Defendant’s Reply to Plaintiff’s Statement of Contested Facts and Plaintiff’s “Undisputed Facts” Pursuant to Local Civil Rule 56.1 Laura A. M
Case 1:15-cv-07433-RWS Document 88 Filed 04/08/16 Page 1 of 7
Case 1:15-cv-07433-RWS Document 92 Filed 04/11/16 Page 1 of 22
EFTA00021875
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