Jack Scarola Florida Bar No.: 169440 Attorney E-Mail(s): jsx@searcylaw.com and mep@searcylaw.com Primary E-Mail: _scarolateam@searcylaw.com Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9451¶
Attorney for J.¶
IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA¶
In re: SUBPOENA TO PAUL G. CASSELL¶
Underlying case:¶
Plaintiff¶
v.¶
GHISLAINE MAXWELL Defendant¶
No. 15-cv-07433-RWS (S.D.N.Y.)¶
REPLY DECLARATION OF .L IN SUPPORT OF MOTION TO QUASH SUBPOENA OR, IN THE ALTERNATIVE, FOR A PROTECTIVE ORDER¶
Case No. 0:16-mc-61262-JEM¶
I, J. declare as follows:¶
I. I am an attorney at law duly licensed in the State of Florida and admitted to practice in the U.S. District Court for the Southern District of Florida. I respectfully submit this reply declaration in support of the Motion to Quash Subpoena or, in the Alternative, for a Protective Order.¶
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Attached as Exhibit I is a true and correct copy of the Victims' Response to Alan Dershowitz's Motion to Interview in the Southern District of Florida in the case of Jane Does v. United States. It is filed under seal.
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Attached as Exhibit 2 is a true and correct copy of and Cassell's Notice of Withdrawal of Summary Judgment Motion.
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Attached as Exhibit 3 is a true and correct copy of Motion to Exceed Presumptive Ten Deposition Limit filed in the Southern District of New York in the case of v. Maxwell. It is filed under seal.
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Attached as Exhibit 4 is a composite exhibit, which are true and correct copies of pages from the Deposition of Ghislaine Maxwell in the underlying case here. It is filed under seal.
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Attached as Exhibit 5 is a composite exhibit, which are true and correct copies of pages from the Deposition of Rinaldo Rizzo in the underlying case here. It is filed under seal.
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Attached as Exhibit 6 is a true and correct copy of Judge Sweet's opinion in this case on June 20, 2016. It is filed under seal.
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Attached as Exhibit 7 is a true and correct copy of a transcript of a hearing before Judge Sweet in the underlying case on June 23, 2016.
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Attached as Exhibit 8 is a true and correct copy an affidavit filed on January 30, 2015, by FBI Agent Slater in the Southern District of Florida in the case of Jane Does v. United States.
DATED this 7th day of July, 2016.¶
By: /s/¶
CERTIFICATE OF SERVICE¶
I certify that on July 7, 2016, I electrically served the foregoing pleading via e-mail on:¶
Laura A. Menninger Jeffrey S. Pa iuca Haddon, and, P.C. 150 East 1 Avenue Denver, CO 80203 Phone: (303) 831-7364 Fax: (303) 832-2628 Imenninger@hmflaw.com¶
Attorneys for Ghislaine Maxwell¶