EFTA00211500.pdf

Haddon. Morgan and Foreman, e c Laura A. Menninger ISO East 10th Avenue II A I> DO N Denver. Colorado 80203 MORGAN FOREMAN April 6. 2016 Via Email Re: Giuffre Maxwell, 15-cv-07433-RWS I appreciate your taking the time to talk to me yesterday. As you know, I represent Ghislaine Maxwell in the United States District Court for the Southern District of New York in a defamation action brought by Plaintiff :aka Jane Doe #3). During the course of discovery disputes Ms. Sigrid McCawley, counsel for represented to the Hon. Robert W. Sweet that my client is "under investigation" by an unidentified law enforcement agency. She argues, therefore, that she can withhold documents based initially on a supposed "investigative privilege" and then later on a "public interest privilege." I am unaware as to how either of these supposed "privileges" would apply to 10•1114,1imi Regardless, because you are the only person employed by the government who I am aware has knowledge of some of the issues with respect to these individuals, I called you to inquire if you are aware of any investigation by law enforcement. In response to my questions I understood you to say: • Ms. Ghislaine Maxwell is not the subject of a current criminal investigation by your office. • You are unaware of any law enforcement agency currently conducting a criminal investigation of Ms. Maxwell. • Ms. Maxwell was not named in any non-prosecution agreement with or concerning Jeffrey Epstein. EFTA00211500 Page 2 If I have misunderstood any of those statements, please let me know. Thank you for your assistance. Best regards, cm. ....ici rHAD N, MORGAN AND FOREMAN, P. um A. Menninger EFTA00211501