Haddon. Morgan and Foreman, e c

Haddon. Morgan and Foreman, e c Laura A. Menninger II A I> DO N MORGAN FOREMAN April 6. 2016 Via Email ISO East 10th Avenue Denver. Colorado 80203 Re: Giuffre Maxwell, 15-cv-07433-RWS I appreciate your taking the time to talk to me yesterday. As you know, I represent Ghislaine Maxwell in the United States District Court for the Southern District of New York in a defamation action brought by Plaintiff :aka Jane Doe #3). During the course of discovery disputes Ms. Sigrid McCawley, counsel for represented to the Hon. Robert W. Sweet that my client is "under investigation" by an unidentified law enforcement agency. She argues, therefore, that she can withhold documents based initially on a supposed "investigative privilege" and then later on a "public interest privilege." I am unaware as to how either of these supposed "privileges" would apply to 10•1114,1imi Regardless, because you are the only person employed by the government who I am aware has knowledge of some of