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Record

Draft: efta02781645

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X

15-cv-07433-RWS

Combined Supplement to Defendant Ghislaine Maxwell's Objections to Motions for Admission Pro Hac Vice by Paul G. Cassell, and

Laura A. Menninger Jeffrey S. Pa liuca HADDON, AND, P.C. East 10th Avenue Denver, CO 80203 303.831.7364

INTRODUCTION

Defendant Ghislane Maxwell, through her attorneys, Jeffrey S. Pagliuca and Laura A. Menninger, supplements her Objection to Motion to Appear Pro Hac Vice of Paul G. Cassell Or, In the Alternative To Modify the Protection Order To Restrict Mr. Cassell's Access to Information Designated as Confidential and Objection to Motion to Appear Pro Hac Vice of James or, Alternatively, to Modify the Protection Order to Restrict Mr. Access to Information Designated Confidential ("Objections" or "Objection")

ARGUMENT

Paul G. Cassell filed his Motion for Admission Pro Hac Vice on April 5, 2016, Doc. #80.

Ms. Maxwell filed her letter Objection to the Motion for Admission Pro Hac Vice filed by Mr. Cassell on April 6, 2016.

Mr. filed his Motion for Admission Pro Hac Vice, Doc. # 86, on April 7, 2016. An Obection to this motion was lodged by Ms. Maxwell on April 8, 2016, Doc. # 88.

Subsequent to the filing of the Objections, Ms. Maxwell obtained a statement issued by Mr. Cassell and Mr. related to and Cassell v. Dershowitz, 15-000072, pending in Ciruit Court in Broward County Florida, in which they admitted that:

Given the events that have transpired since the filing of the documents in the federal court and in this action in which Dershowitz was accused of sexual misconduct, including the court order striking the alle ations in the federal court filings, and the records and other documents by the parties, and Cassell acknowledge that it was a mistake to have filed sexual misconduct accusations against Dershowitz; and the sexual misconduct accusations made in all public filings (includini•chibits) are hereby withdrawn. Dershowitz also withdraws his accusations that and Cassell acted unethically.

See, Pagliuca Decl. at Exhibit A, online article published on the Gates Institute website captioned "Lawyers Acknowledge Mistake In Filing Sexual Misconduct Charges Against Professor Dershowitz".

Subsequent to the filing of the Objections, Ms. Maxwell obtained a copy of the complaint filed against Mr. captioned Epstein v. Rothstein, and L.M. filed in the Circuit Court of the Fifteenth Judicial Circuit in and for Palm Beach County, Florida. See, Pagliuca Decl. at Exhibit B.

The information attached is relevant to the issues raised in the Objections to the Motions for Admission Pro Hac Vice and will be relied on by counsel for Ms. Maxwell at the hearing on these motions scheduled for April 21, 2016.

Dated: April 19, 2016

Respectfully submitted,

/s/ Jeffrey S. Pagliuca

Laura A. Menninger (LM-1374)

Jeffrey S.likca

HADDON, AND P.C.

150 East 10 Avenue

Denver, CO 80203

Phone: 303.831.7364

Fax: 303.832.2628

Imenninger@hmflaw.com

Attorneys for Ghislaine Maxwell

CERTIFICATE OF SERVICE

I certify that on April 19, 2016, I electronically served this COMBINED SUPPLEMENT TO DEFENDANT GHISLAINE MAXWELL'S OBJECTIONS TO MOTIONS FOR ADMISSION PRO HAC VICE BY PAUL G. CASSELL, AND via ECF on the following:

Sigrid S. McCawley BOIES, $CHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley@bsfllp.com

/s/ Nicole

Nicole

Draft: efta02781645

Other records

Prepared source

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-RWS Combined Supplement to Defendant Ghislaine Maxwell's Objections to Motions for Admission Pro Hac Vice by Paul G. Cassell, and Laura A. Menninger Jeffrey S. Pa liuca HADDON, AND, P.C. East 10th Avenue Denver, CO 80203 303.831.7364 INTRODUCTION Defendant Ghislane Maxwell, through her attorneys, Jeffrey S. Pagliuca and Laura A. Menninger, supplements her Objection to Motion to Appear Pro Hac Vice of Paul G. Cassell Or, In the Alternative To Modify the Protection Order To Rest…