EFTA00091353.txt

"GHISLAINE MAXWELL, Defendant. 15-cv-07433-RWS"

"Laura A. Menninger ... Attorneys for Ghislaine Maxwell"

"Jeffrey S. Pagliuca (pro hac vice) ... Attorneys for Ghislaine Maxwell"

"I certify that on May 16, 2016, I served the attached document ... via email to the following counsel of record: Sigrid S. McCawley"

"Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will Defendant move for a Protective Order"

"Plaintiff, v. GHISLAINE MAXWELL... 15-cv-07433-RWS"

"Plaintiff was abused by Jeffrey Epstein"

"Plaintiff and Plaintiff's counsel, including without limitation Mr."

"Produce any Joint Defense Agreement entered into between You and Jeffrey Epstein from 1999 to the present."

"Plaintiff and her counsel, including without limitation Mr."

"Plaintiff's counsel will not file a Motion to Compel a Response to this Request, nor will Defendant move for a Protective Order"

"served the attached document ... via email to the following counsel of record: Sigrid S. McCawley"

"served the attached document ... via email to the following counsel of record: Meridith Schultz"

"served the attached document ... via email to the following counsel of record: Paul G. Cassell"

"paying Ross Gow... for any work he performed on Your behalf"

"all of which document her denial that she did "recruit[] any female under the age of 18 for any purpose.""

"Produce any Joint Defense Agreement entered into between You and Alan Dershowitz from 1999 to the present"

"Produce all contracts, including but not limited to indemnification agreements and employment agreements, between You and Jeffrey Epstein"

"Defendant refers to the public documents and news reports regarding Plaintiff's allegations of sexual abuse"

"Plaintiff's allegations of sexual abuse and investigation of the same"

"Ms. Maxwell has made available documents related to some of Ms. [REDACTED] false allegations of sexual assaults"

"funding for the TarraMar Project or any other not-for-profit entities with which You are associated"

"s/Laura A.Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) AND FOREMAN, P.C."

"Jeffrey S. Pagliuca (pro hac vice) AND FOREMAN, P.C."

"any dwelling paid for -in whole or in part by Defendant or Jeffrey Epstein"

"any dwelling paid for -in whole or in part by Defendant or Jeffrey Epstein"