Haddon, Morgan and Foreman, P.C.
OrganizationRelationship Network
Event Timeline
| Connected Entity | Relationship Type |
Strength
(mentions)
|
Documents | Actions |
|---|---|---|---|---|
|
person
GHISLAINE MAXWELL
|
Professional |
5
|
1 | |
|
person
Jeffrey Pagliuca
|
Professional |
5
|
1 | |
|
person
Laura Menninger
|
Professional |
5
|
1 | |
|
person
GHISLAINE MAXWELL
|
Client |
5
|
1 | |
|
person
Laura A. Menninger
|
Employment |
5
|
1 | |
|
person
Laura A. Menninger
|
Employee |
5
|
1 | |
|
person
Nicole Simmons
|
Employment |
1
|
1 | |
|
person
Jeffrey S. Pagliuca
|
Employment affiliation |
1
|
1 |
| Date | Event Type | Description | Location | Actions |
|---|---|---|---|---|
| 2020-10-08 | Legal filing | Filing of an 'Unopposed Motion for Leave to File Unredacted Reply Brief under Seal' by Ghislaine ... | United States Court of Appe... | View |
| 2020-09-24 | N/A | Filing of Unopposed Motion for Leave to File under Seal | United States Court of Appe... | View |
22-1426_Documents.pdf
This document consists of a Docketing Notice from the Second Circuit Court of Appeals dated July 8, 2022, for the appeal of Ghislaine Maxwell (Case 22-1426), and a Notice of Appeal and Criminal Docket from the Southern District of New York (Case 1:20-cr-00330-AJN) filed July 7, 2022. It details Maxwell's conviction and sentencing, including multi-year imprisonment terms and a $750,000 fine for charges related to conspiracy to entice minors for illegal sex acts, transport minors for sexual activity, and sex trafficking, with some counts dismissed or deemed multiplicitous.
20-3061_Documents.pdf
This document is the complete appellate record for case 20-3061, an interlocutory appeal by Ghislaine Maxwell against the United States. Maxwell appealed a District Court order denying her motion to modify a protective order, seeking permission to share confidential criminal discovery materials under seal with the judge in a related civil case (Giuffre v. Maxwell) to challenge the government's acquisition of evidence. The Second Circuit Court of Appeals dismissed the appeal for lack of jurisdiction, ruling that the protective order decision was not a final judgment or an appealable collateral order, and denied Maxwell's motion to consolidate the criminal appeal with the civil appeal.
036.pdf
A legal filing (Sur-Reply) by Ghislaine Maxwell's attorneys arguing that Plaintiff Bradley Edwards must produce solicitation letters sent to former Epstein employees and their responses. The defense argues Edwards waived work-product privilege by failing to produce a privilege log and that the letters sent to third parties do not constitute work product.
033.pdf
This document is a Reply Memorandum filed by attorney Bradley J. Edwards in support of his motion to quash a subpoena served on him by Ghislaine Maxwell. Edwards argues that Maxwell's requests for his communications with 'prospective witnesses' are overbroad, unduly burdensome, and seek protected attorney work-product. The filing notably alleges that Maxwell has failed to explain her presence on 23 flights with a teenaged Virginia Giuffre or the message pads documenting underage girls calling Epstein's mansion for 'massages'.
024.pdf
This document is a legal notice filed by Ghislaine Maxwell's attorneys on December 16, 2016, in the Southern District of Florida regarding a subpoena served on Bradley J. Edwards. Maxwell argues that rulings made by the Southern District of New York on a similar subpoena served on Paul Cassell (another attorney for Virginia Giuffre) should be binding (res judicata) on the Edwards subpoena. The filing includes a table comparing the requests in both subpoenas and the corresponding rulings from the SDNY court, asking the Florida court to issue a consistent order requiring production of certain documents and granting the motion to quash for others.
023.pdf
This document is a formal notice filed on December 16, 2016, in the Southern District of Florida, by attorneys for Ghislaine Maxwell. It informs the court and opposing counsel (specifically Bradley J. Edwards' attorney Jack Scarola) that 'Exhibit B' related to a subpoena status notice has been filed under seal. The underlying case referenced is Virginia L. Giuffre v. Ghislaine Maxwell in the Southern District of New York.
022.pdf
This document is a motion filed on December 16, 2016, by Ghislaine Maxwell's attorneys in the Southern District of Florida. The motion requests permission to file 'Exhibit B' under seal, noting that the exhibit is a sealed order from the Southern District of New York in the underlying 'Giuffre v. Maxwell' case. The document lists legal counsel for Maxwell and for Bradley J. Edwards, who is the subject of a subpoena in this miscellaneous action.
015.pdf
This document is a Motion to Seal filed on July 7, 2016, by attorney Jack Scarola on behalf of Bradley J. Edwards in the U.S. District Court for the Southern District of Florida. Edwards seeks to seal exhibits attached to his Motion to Quash a subpoena, specifically referencing confidential depositions of Ghislaine Maxwell and Rinaldo Rizzo, as well as documents related to Alan Dershowitz, which are already under seal in the Southern District of New York. The motion argues that sealing is necessary to comply with protective orders from the underlying case.
013.pdf
This document is a reply filed by Bradley J. Edwards in support of his motion to quash a subpoena served on him by Ghislaine Maxwell in the case of Giuffre v. Maxwell. Edwards argues that the subpoena imposes an undue burden on him as a non-party and opposing counsel, seeking information that is already in Maxwell's possession, privileged, irrelevant, or available from other sources. The brief details the history of related litigation, including the CVRA case and a defamation suit against Alan Dershowitz, to support the argument that the subpoena is harassing and unnecessary.
012.pdf
This document is a motion filed on July 7, 2016, in the Southern District of Florida by attorney Jack Scarola on behalf of Bradley J. Edwards. Edwards requests permission to file a reply exceeding the standard page limit (up to 25 pages) in support of his motion to quash a subpoena served by Ghislaine Maxwell. The motion explains that the extra length is necessary to address allegations made by Maxwell regarding Edwards' prior filings and alleged discovery withholding by his client, Virginia Giuffre.
010.pdf
Declaration by Jeffrey S. Pagliuca, attorney for Ghislaine Maxwell, filed on June 30, 2016, in the Southern District of Florida. The document lists 18 exhibits (A-R) supporting Maxwell's opposition to Bradley J. Edwards' motion to quash a subpoena. Several exhibits are filed under seal, while others include procedural documents from related cases (Cassell v. Dershowitz, Epstein v. Rothstein, Jane Doe v. US) and communications regarding discovery and subpoenas.
007.pdf
This document is a 'Notice of Filing' submitted to the U.S. District Court for the Southern District of Florida on June 29, 2016. It serves to notify the court and opposing counsel that Defendant Ghislaine Maxwell has filed Exhibits A, G, H, I, and N under seal. These exhibits are attached to a declaration by her attorney, Jeffrey S. Pagliuca, in support of her opposition to Bradley J. Edwards' motion to quash a subpoena.
006.pdf
This document is a motion filed on June 29, 2016, by attorneys for Ghislaine Maxwell in the Southern District of Florida. The motion requests permission to file specific exhibits (A, G, H, I, and N) under seal because they were designated as confidential in the underlying case (Giuffre v. Maxwell) in the Southern District of New York. The document includes a certificate of service indicating the motion was served electronically to attorney Jack Scarola representing Bradley J. Edwards.
005.pdf
This document is a Motion to Appear Pro Hac Vice filed on June 29, 2016, in the Southern District of Florida. Attorney Denise D. Riley requests that attorney Jeffrey S. Pagliuca of the Colorado firm Haddon, Morgan and Foreman be admitted to represent Defendant Ghislaine Maxwell in matters related to a subpoena issued to Bradley J. Edwards. The document includes contact information for the attorneys involved and a certificate of service to opposing counsel Jack Scarola.
005-02.pdf
This document is a proposed court order filed on June 29, 2016, in the Southern District of Florida, granting attorney Jeffrey S. Pagliuca permission to appear Pro Hac Vice on behalf of Ghislaine Maxwell. The order relates to a subpoena issued to Bradley J. Edwards in connection with the underlying case of Virginia L. Giuffre v. Ghislaine Maxwell. It also establishes electronic filing notifications for Pagliuca and his legal assistant, Nicole Simmons, at the firm Haddon, Morgan and Foreman, P.C.
001-05.pdf
This document outlines Ghislaine Maxwell's formal objections and responses to Virginia Giuffre's second request for production of documents in the 2015 civil case. Maxwell's counsel objects to numerous requests on grounds of privilege, relevance, and burden, specifically refusing to produce financial documents (tax returns, bank statements, asset lists) pending a motion for a protective order. The document also addresses requests for Joint Defense Agreements with Jeffrey Epstein and Alan Dershowitz, communications regarding sexual abuse allegations, and funding sources for the TerraMar Project, including any from the Clinton Foundation.
001-01.pdf
Legal declaration by attorney Bradley J. Edwards filed on June 13, 2016, in support of a motion to quash a subpoena from Ghislaine Maxwell. Edwards details his representation of Virginia Giuffre and the undue burden of reviewing over 200,000 emails for communications with journalists. He explicitly states that Ghislaine Maxwell and Jeffrey Epstein share a joint defense agreement and mentions Giuffre's association with the organization 'Victims Refuse Silence, Inc.'
EFTA00032796.pdf
This document is an email dated October 19, 2021, from Nicole Simmons of Haddon, Morgan and Foreman, P.C. to Judge Nathan's chambers in the NYSD. The email serves to submit 'Ms. Maxwell's Motions in Limine' and supporting documents for the case U.S. v. Maxwell (Case No. 20 Cr. 330), done at the request of attorney Jeffrey Pagliuca. The document contains redactions of contact information.
EFTA00032234.pdf
This document is an email dated August 18, 2020, from Nicole Simmons of Haddon, Morgan and Foreman, P.C. to Judge Nathan's chambers. The email serves to transmit a sealed Letter Motion, Affidavit, and ten exhibits on behalf of defendant Ghislaine Maxwell regarding a 'Request to Modify Protective Order' in the case United States v. Ghislaine Maxwell. The filing was made at the request of attorney Jeffrey S. Pagliuca.
EFTA00032021.pdf
This document is a letter from the U.S. Department of Justice to Ghislaine Maxwell's defense team, dated September 15, 2021. It serves as notice that the government intends to call FBI Computer Forensic Examiner Stephen [Redacted] as an expert witness to testify regarding the extraction of data from seized electronic devices. The letter also reiterates previous government requests from 2020 and early 2021 for reciprocal discovery and expert witness notices from the defense.
EFTA00031440.pdf
This document is a discovery production letter from the U.S. Attorney's Office for the Southern District of New York to Ghislaine Maxwell's defense team, dated April 14, 2021. It details the production of a single photograph (Bates number SDNY_GM_02753398) designated as 'Confidential' under a Protective Order. The letter is signed by U.S. Attorney Audrey Strauss, with the specific Assistant U.S. Attorneys' signatures redacted.
EFTA00031437.pdf
A discovery letter from the U.S. Department of Justice to Ghislaine Maxwell's defense team dated April 14, 2021. The letter documents the production of a single item, a photograph (Bates SDNY_GM_02753398), which is designated as confidential under a July 2020 Protective Order. The specific names of the Assistant U.S. Attorneys signing the document are redacted.
EFTA00031113.pdf
A letter from US Attorney Damian Williams to Ghislaine Maxwell's defense team dated November 24, 2021, detailing the production of discovery materials. The production includes Jencks Act and Giglio materials for potential trial witnesses, as well as courtesy materials for individuals the government does not currently intend to call. The letter also clarifies protective order designations for the enclosed documents.
EFTA00031016.pdf
This document is a discovery letter dated May 3, 2021, from the U.S. Department of Justice (SDNY) to Ghislaine Maxwell's defense team. It accompanies the production of photographs (Bates range SDNY_GM_02753399 to SDNY_GM_02753431) designated as confidential under a Protective Order.
EFTA00030992.pdf
This document is a discovery letter from the U.S. Attorney's Office (SDNY) to Ghislaine Maxwell's defense team, dated August 21, 2020. It outlines the production of various evidentiary materials, including Boies Schiller documents, emails, search warrant photos, Jeffrey Epstein's deposition recordings (2010), travel records, and SORNA records. The letter explicitly notes that 'highly confidential' materials containing sexualized images are being provided only to counsel, not the defendant, and refuses to produce a separate FBI obstruction file regarding a redacted former employee of Epstein deemed irrelevant to the case.
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