EFTA00021875.pdf

"Jeffrey S. Pagliuca Haddon, Morgan and Foreman, P.C."

"Laura Menninger <[email protected]>"

"the protective order explicitly precludes the use of criminal grand jury materials in Maxwell's civil cases... our response to Jeff and Laura"

"our response to Jeff and Laura, if we wanted to, that given their awareness of the materials, we assume they will retract the obviously false claims a"

"Christian Everdell <CEverdell@CohenGressercom>"

"From: Jeff Pagliuca Subject: Letter regarding discovery attached. Dear Counsel"

"I think there's case law that strongly suggests we need to disclose the victim names."

"they should feel free to raise the issue with Nathan and we'll respond"

"our response could basically be a copy-paste of the letter I wrote to Netburn"

"the protective order explicitly precludes the use of criminal grand jury materials in Maxwell's civil cases"